ML20135E493
ML20135E493 | |
Person / Time | |
---|---|
Site: | Fermi |
Issue date: | 09/11/1985 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20135E349 | List: |
References | |
50-341-85-27-01, 50-341-85-27-1, NUDOCS 8509160417 | |
Download: ML20135E493 (46) | |
See also: IR 05000341/1985027
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SALP 6
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SALP BOARD REPORT
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U.' S. NUCLEAR REGULATORY COMMISSION
, REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE !
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- 50-341/85027
i Inspection, Report ;
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l Detroit Edison Company
- Name of Licensee
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l ' Fermi 2
i Name of Facility ;
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! October 1,1984 through June 30, 1985 !
!- Assessment Period I
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management to
promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on June 27,
1985, to review the collection of performance observations and data to assess
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the licensee's performance in accordance with the guidance in NRC Manual
- ' Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of
the guidance and evaluation criteria is provided in Section II of this report.
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This report is the SALP Board's assessment of the licensee's safety performance
at Fermt Unit 2 for the period October 1,1984, through June 30, 1985.
SALP Board for Fermi 2:
Name Title
! J. A. Hind Director, Division of Radiation Safety
1 and Safeguards (DRSS)
2
R. L. Spessard Director, Division of Reactor Safety (DRS)
i C. E. Norelius Director, Division of Reactor- Projects (DRP)
i C. J. Paperiello Chief, Emergency Preparedness and
Radiation Safety Branch
L. A. Reyes Chief, Operations Branch, DRS
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N. J. Chrissotimos Chief, Reactor Projects Section ID
J. R. Creed Chief, Safeguards Section
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M. A. Ring Chief, Test Programs Section
M. P. Phillips Chief, Emergency Preparedness Section
- D. H. Danielson Chief, Materials Section DRS
T. Madeda Security Inspector, DRSS
, S. G. DuPont Reactor Inspector, TPS
S. Stasek Project Inspector, Reactor Projects
Section 10
, Z. Falevits Reactor Inspector, DRS
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R. Hasse Reactor Inspector, DRS
M. D. Lynch Licensing Project Manager, NRR
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II. CRITERIA
The licensee's performance is assessed in selected functional areas
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depending whether the facility is in a construction, pre-operational or
operating phase. Each functional area normally represents areas
significant to nuclear safety and the environment, and are normal
. programmatic areas. Some functional areas may not be assessed because !
of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
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functional area.
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1. Management involvement in assuring quality
- 2. Approach to resolution of technical issues from a safety standpoint
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3. Responsiveness to NRC initiatives
4. Enforcement history
i 5. Reporting and analysis of reportable events
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6. Staffing (including management)
l 7. Training effectiveness and qualification.
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{ However, the SALP Board is not limited to these criteria and others may
i have been used where appropriate.
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Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definition of
i these performance categories is:
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Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety or
construction is being achieved. -
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Category 2: NRC attention should be maintained at normal. levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources.are adequate and are
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reasonably effective such that satisfactory performance with respect to
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operational safety or construction is being achieved.
Category 3: Both NRC and licensee attention should be increased.
Licensee management. attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; ljcenseenresources appear to-
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety be construction is being
, achieved.
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Trend: The SALP Board has also categorized the performance trend in each ,
functional area rated over the course of the SALP assessment period. The '
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categorization describes the general or prevailing tendency (the perfor-
, mance gradient) during the SALP period. The performance trends are
defined as follows:
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Improved: Licensee performance has generally improved over the course
l of the SALP assessment period.
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! Same: Licensee performance has remained essentially constant over i
the course of the SALP assessment period.
Declined: Licensee performance has generally declined over the course
j of the SALP assessment period.
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III. SUMMARY OF RESULTS
Overall, the licensee's performance was found to be acceptable and showed
an improving trend. The licensee was found to have aggressive management
attention and a high level of performance in the areas of Emergency
Preparedqcss,' Fueling, and Preoperational and Startup Phase Testing.
! Performnce in the Fire Protection area was found to need increased ~
management attention as well as maintenance of the' current increased NRC
staff attention during subsequent inspections.
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, , Rating't$st Rating This '
Functional Area Feriod-. ..s Period .T' end
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A. Piping. Systems 1
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j and Supports 2 2 Same
B. Electrical Power
~ p Supply / Distribution
'and Instrumentation / -
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Control Systems 3 ~2 , , Improved
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C. Fire Protection 3 3, Same
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D. Preoperational and-
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.Startup Phase Testing 2 1 Improved
E. ~ Plant Operations NR y 2 NR
F. Radiological Controls,, 2 '
2 Same
'G. Maintenance NR 2 NR
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H. , Surveillance NR 2 _
NR
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1. Emergency Preparedness 1 ., [ '1
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Same
J. Security 2 l 2
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Same
K. Fueling '
NR 1 NR
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Administrative Controis
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, 2' 2 Improved
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- ' ;M. Licensing Activities 2 2 .Same
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i *NR = not rated or not rated- separately.
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IV. PERFORMANCE ANALYSIS
A. Piping Systems and Supports
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1. Analysis
j Work activities in this area are essentially complete. Examina-
tion of this functional area consisted of four inspections by
- regional based inspectors (50-341/84-52; 50-341/84-55; 50-341/
i 84-59; and 50-341/85-11). Areas examined included (1) actions
related to previous inspection findings, 10 CFR 50.55(e) items,
IE Bulletins and IE Circulars, (2) Sargent and Lundy design
practices, (3) effects of postulated high and moderate energy ;
pipe breaks outside primary containment, and (4) allegations
brought to the attention of the NRC.
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Two violations were identified; Severity Level IV violation
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(50-341/85011(DRS)) - Failure to take appropriate corrective
action relating to disposition of an anchor bolt spacing deft-
! ciency report, and Severity Level V violation (50-341/85011(DRS))
- Inadequate design control for installation of anchor bolts.
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The violations are not repetitive of noncompliance identified l
during the previous assessment period and they do not appear
to have programmatic implications.
Concerns reported to the Resident Inspector relating to the
reactor vessel jet pump diffuser to adapter welds were
. inspected. Neither the governing code nor the applicable
i procedures were violated by the licensee or its agents. Based
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on satisfactory completion of appropriate examinations and
resolution of the radiographic issue, these welds were
acceptable.
! For the areas examined, the inspectors determined that the
management control systems met regulatory requirements. Except
as noted above records were found to be complete, well main-
- tained and avai.lable. Discussions with licensee and contractor
- personnel indicated that they were knowledgeable in their job.
No major strengths or weaknesses were noted.
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2. Conclusion
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The licensee is rated Category 2 in this area. Licensee
! performance remains the same.
- 3. Board Recommendations
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None.
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B. Electrical Power Supply / Distribution and Instrumentation / Control
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System
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1. Analysis
During this assessment period, licensee activities in this area
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were observed during ten inspections. The areas inspected
include: electrical separation requirements including design
and field installations; review of as-built electrical and I&C
, verification; deviation dispositioning programs; review of licen-
see corrective action and resolutions to the Duke Construction
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Assessment Team recommendations; independent design review of !
drawings for adequacy; control and conformance of as-built
! configurations of installed electrical components; review of QA
installation records; review of testable check valve and breaker
, position indicators; cable routing; instrument calibration; and
- investigation of allegations. Six items of noncompliance were
4 identified as follows:
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(a) Severity Level IV - Failure to assure that deficiencies in
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the control logic schematic diagrams of the RHR System were
properly identified, corrected, and controlled (Inspection
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Report No. 50-341/84-57).
(b) Severity Level IV - Failure to assure that the as-built
general arrangement drawings 61721-2281-19, Revision "J"
and 61721-2281-5, Revision "H", reflected as-built
conditions for instrument racks H21-P021 and H21-P005 in
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the following areas: discrepancies were identified in
catalog numbers, identification and location of instruments,
i valves, and tubing (Inspection Report 50-341/84-50).
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! (c) Severity Level IV - Failure to take measures to control
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the issuance of documents prescribing activities affecting
1 quality, and to assure that documents, including changes,
j are reviewed for adequacy and distribution to and used at
the location where the prescribed activity is performed
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(Inspection Report 50-341/84-62).
- (d) Severity Level IV - As installed wiring of protective
undervoltage relays 27ZX, 27YZ and 27XY, mounted in
position IA of 480v safety-related switchgear 72F and
undervoltage relay 27XY, mounted in position IA of
safety-related switchgear 72E, did not conform to
- connections delineated on wiring diagrams 650721-2511-50,
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Revision "K", and 650721-2511-43, Revision "H", respec-
tively (Inspection Report No. 50-341/84-62).
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(e) Severity Level IV - The inspector identified twenty-five
missing or burned out breaker position status indicating
lights in twenty-one positions of safety-related switch-
gears (Inspection Report No. 50-341/84-62). '
(f) Severity Level IV - Failure to assure that changes and
revisions to drawings were adequately reviewed and
controlled when used in Checkout and Initial Operation
(C&IO) testing of safety-related systems (Inspection
Report No. 50-341/84-68).
During this period, the licensee has initiated a comprehensive
enrrective action program as a result of NRC findings in major
areas such as: as-built configuration deficiencies of
installed electrical and I&C components as compared to the
applicable design drawings, (e.g., control logic schematic
diagrams, connection-diagrams, front elevation drawings,
specifications, etc.); sizing of safety-related fuses relative
to the design of circuit requirements, sizing of thermal
overloads and drawing control.
The implementation of corrective actions has been closely
monitored through increased NRC inspection activities. The
corrective action taken to resolve the as-built issue is still
ongoing. While most hardware deficiencies have been resolved,
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resolution of the software item deficiencies is still in
progress. The fuse and thermal overload issues have been
completed. Corrective action has been adequate in providing
more accurate as-built design drawings which reflect design
and regulatory requirements.
The NRC inspectors reviewed the licensee response to, and
corrective action taken to address the Duke Power recommenda-
tions. Corrective action was timely and effective in most
Cases.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated Category 3 in this functional area in the previous
assessment period. The licensee performance appears to have
generally improved following the previous SALP assessment
period.
3. Board Recommendations
Licensee management should continue placing major emphasis on
maintaining accurate as-built design documents and ensuring
, adequate completion of the comprehensive corrective action
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. programs now in place. Close attention should be placed on
following procedures specifically in the plant maintenance
area. ,
i C. Fire protection
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1. Analysis
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i During this assessment period, four inspections were performed i
i (50-341/84-49(DRS),50-341/85012(DRS),50-341/85014(DRS),and l
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50-341/85025(DRS)) by regional inspectors including one alle-
! gation followup. .These inspections did not overlap the previous
. SALP period. These inspections were performed to assess con-
I formance of the as-built plant conditions to FSAR commitments,
i fire protection program implementation, and post fire safe
i shutdown capability.
- During the first of the four inspections-conducted, two devia-
tions were identified as follows: (1) the installation of
portable fire extinguishers having less extinguishing capability
than those portable extinguishers identified in the FSAR, and
1 (2) the failure to design and install fire detectors in
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accordance with FSAR commitments. In addition, the licensee's
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Quality Assurance (QA) program for construction was found to be
inadequate in the area of fire protection and the QA program
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governing operations was found to be inconsistent with FSAR
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commitments.
During the three subsequent inspections, the inspectors noted
that the licensee was devoting considerable attention and
resources to resolving NRC identified problems in the fire pro-
i tection area. However, despite the increased licensee effort,
- the inspectors found additional examples of deficiencies in fire
detector installations and fire rated assemblies.
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There was one allegation followup inspection that pertained to
one fire protection sprinkler system having improperly installed
j horizontal sidewall sprinkler heads. It was determined that six
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sprinkler heads were questionable regarding their installed
position. These heads were replaced by the Itcensee and veri-
- fied by a Region III fire protection specialist.
! Other open and unresolved items identifying varying degrees of
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deficiencies were discovered in the areas of Construction, Fire
Detection System Design, and the maintaining of emergency light-
1 ing units. The licensee has implemented compensatory measures
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in several areas of the plant as a result of a failure to provide
proper design features to limit fire damage to redundant safe
shutdown trains.
The licensee was rated Category 3 in this functional area during
the SALP 5 evaluation period. As documented in the SALP 5
report (50-341/84-23) and associated transmittal letters, the
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primary reasons for the Category 3 rating were a lack of manage-
ment attention to the development and implementation of the Fire
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Protection Program, a failure on the part of management to fully
understand its commitments to the NRC, and a failure on the part
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of management to ensure that those commitments which were under-
- stood were properly implemented. It was noted in that report
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that management appeared to be taking aggressive actions to
i correct deficiencies identified by the NRC. As noted above, in
- , spite of increased management attention and the expenditure of
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considerable resources, the NRC continued to identify problems
in this functional area. While many NRC identified issues were
resolved as a result of the increased management attention, the
fact that other problems were identified by the NRC is indica-
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tive of a failure on the part of the licensee to take the
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initiative in the fire protection area.
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2. Conclusion
i The licensee is rated Category 3. While evidence of increased
management attention was noted, the NRC has continued to iden-
tify examples of previously identified problems most notably in
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the areas of fire rated assemblies and fire detection systems.
Licensee performance has remained essentially constant over ;
the evaluation period.
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3. Board Recoamendations
Management attention should be directed at ensuring continuing
compliance. An increase in the level of effort devoted to self
assessment is warranted. An increased level of NRC attention ;
should be maintained. L
l D. Preoperational and Startup phase Testing
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) 1. Analysis I
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! The preoperational and startup phase testing efforts were ,
! inspected by both region based and resident inspectors. The i
! region based inspectors performed five inspections and the i
resident inspectors performed portions of inspections during :
j this assessment period. This assessment period reflects
continuing improvements in the licensee's performance. The
inspection ef fort included in-depth reviews of preoperational [
and startup phase test procedures and preoperational test i
results, witnessing preoperational and startup phase test ;
performance, reviews of administrative controls and imple- I
menting procedures, observations of corrective actions and I
independent inspection. During this assessment period there "
j were no items of noncompliance identified in the startup i
testing phase. Two violations were identified during review of (
j the containment integrated leak rate test:
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Severity Level IV - Failure to follow procedures during testing
i of personnel access hatch (Inspection Report No. 50-341/84-53).
l Severity Level IV - Failure to take adequate corrective action ;
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to preclude repetition of incorrect valve position indication !
, (Inspection Report No. 50-341/84-53). j
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There were no major technical problems identified during this
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assessment period with the exception of the foreign debris found
- in safety-related piping systems. This problem was-discussed
j in detail in the SALP 5 assessment and one recurrence was identi-
- fied during this assessment period. The licensee found debris
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in the scram discharge volume which was evaluated as being
! debris from maintenance prior to the system flush.
) Even though there has been one recurrence, the licensee's
administrative measures have prevented any new debris
j intrusions into safety-related piping.
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Management's initiatives to correct previous problems were
] thorough and aggressive. As a result of this attention, none ;
of the previously identified problems recurred and no items of '
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noncompliance were issued for the preoperational test program. [
2. Conclusion I
The licensee is rated Category 1 in this area based on the ,
- management improvements in the implementation of corrective '
actions that have prevented recurrence of problems identified
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- in both SALP 4 and 5 assessments.
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None,
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E. Plant Operations
1. Analysis
! The operational phase efforts were inspected by both region-
- based and resident inspectors. The resident inspectors ,
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performed six inspections and the region-based inspectors l
j performed portions of two inspections during this assessment
- period. This functional area was not assessed during the
previous SALP period. :
! The licensee received their operating license during the !
! assessment period. The assessment in this functional area '
j was divided into two phases - those issues required to be
i completed for the issuance of the operating license, and
j the operation of the plant af ter issuance of the license.
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The inspection effort included in-depth reviews of procedures
in preparation for the issuance of the operating license,
reviews of administrative controls and implementing procedures,
observations of corrective actions and operator actions, and
independent inspection.
Four items of noncompliance were identified as follows:
a. Severity Level IV - Failure to follow administrative
procedures (Report No. 50-341/84-40).
b. Severity Level IV - Procedures were found to be inadequate
or incomplete. (ReportNo. 50-341/84-40).
c. Severity Level V - The use of inadequate procedures to
collect battery data. (Report No. 50-341/84-46),
c. Severity Level V - An Engineering Design Package (EDP) was
not implemented in accordance with the EDP implementation
procedure (Report No. 50-341/85021).
Noncompliances a. and d. represented personnel errors in that
procedures were not followed or work was not performed in an
acceptable manner.
Noncompliances b. and c. were programmatic in nature and
represent inadequate procedural reviews.
The licensee walked through all surveillance procedures prior
to issuance and implementation. In addition, the licensee was
required to re-review all other procedures for technical
adequacy prior to operating license issuance. The result of
this action is that there have been no Licensee Event Reports
(LERs) written as a result of inadequate procedures.
Twenty-seven incidents have occurred since license issuance
which have or will result in the issuance of an LER. Seven-
teen LERs have been issued to date. These can be categorized
as follows:
7 personnel related
5 - hardware related
5 - design related
The seven personnel errors can be categorized as failure to
follow procedures and/or technical specification requirements
and communication problems. The hardware-related items have
no pattern while the design / technique-related incidents all
occurred while performing surveillances on reactor level
instrumentation. The vessel level instrumentation utilizes
a common reference leg which frequently results in a scram
signal when the reactor is not at operating pressure.
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! There does not appear to be any significant issues identified
, in the LERs nor does there appear to be any significant issues
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in the remaining ten items yet to be reported. The greatest t
i problem area has been the failure to follow procedures and/or
technical specification requirements. In addition to the seven
identified by LERs, two of the remaining ten items.that must be -
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addressed fall into this same category. !
} The Plant Operations area is fully staffed. Senior management
overview, both onsite and from the corporate office, was evident
- throughout the assessment period. l
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Currently, there are 20 senior reactor operators (SR0s) and 21
) reactor operators (R0s) onshif t. During the assessment period, .
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! NRC licensing exams were administered to four SRO candidates
! and seven R0 candidates. Of these, two SR0 candidates passed
and all of the R0 candidates passed. [
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j The operators appear to be well trained and cautious. The
j inspectors have observed their thoroughness in carrying out
j their duties. This is reflected in the lack of LERs relating ;
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to operator error.
- Region III conducted a team inspection during the assessment
j period to evaluate the licensee's ability to operate the plant ,
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in an acceptable manner. The team, which consisted entirely ,
of Resident Inspectors from operating sites, performed in-depth
j reviews of plant operations, maintenance, surveillance, and ;
i radiation protection programs and concluded that the plant was ,
- implementing these programs satisfactorily and that the licensee ;
j was ready to support full power operation. ;
t 2. Conclusion :
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, The licensee is rated Category 2 in this area. The licensee !
was not rated in this area during the last assessment period. ;
No trend could be established in this area. -
3. Board Recommendations
, The Board recommends that the licensee maintain a high level of
i attention to this area due to the limited amount of operating
i experience accumulated to date. Concerted effort by licensee
- management may be required to ensure that indicated performance
{ remains at an acceptable level,
j F. Radiological Controls
1. Analysis l
1 !
i Licensee performance received a Category 2 rating during the I
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J SALP 5 period which ended September 30, 1984. During the
- current assessment period, inspections were performed in ,
j November-December, 1984, (50-341/84043(DRSS)) and March 1985, [
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(50-341/85017(DRSS)) to review the licensee's preparations for
fuel load in the areas of radiation protection and radwaste; no
violations or deviations were identified. No inspections of the
l confirmatory measurements or environmental monitoring programs
l occurred during this period.
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It was determined that the licensee had satisfactorily completed
i activities required for fuel load. Five activities need to be
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completed before exceeding five percent power and are addressed
- by open items and/or license conditions. One additional item
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concerning operability of an interim solid radwaste system is
j required to be completed prior to the warranty run.
Licensee progress on these items has been generally satisfactory.
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Items involving operability of the permanent liquid radwaste
i system, operability of the post accident sampling system, and
installation of a collimator for the germanium detector used for
post accident sample counting, are essentially complete and
ready for final NRC review.
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The licensee recently submitted a Process Control Program (PCP)
< covering operation of a vendor supplied interim solid radwaste
t processing system to NRR for approval. The vendor system is
i expected to be operational before exceeding five percent power
and will be used until completion of the permanent solid
radwaste system.
Management involvement, resolution of technical issues, and
responsiveness to NRC issues have been satisfactory during this
assessment period.
l 2. Conclusion
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l The licensee is rated Category 2 in this area. This is the
same rating as in the previous assessment period. Licensee
l performance has remained essentially the same over the course
of the current assessment period.
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3. Board Recommendations .
None.
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G. Maintenance
1. Analysis
This functional area was examined by the resident inspectors
on a routine basis during the readiness assessment team inspec-
tion, and by a region based inspector during one inspection
within the assessment period. The region-based inspection was
performed to determine the adequacy of implementation of the
licensee's operating phase maintenance and modification prcgrams.
One violation was identified in this area: Severity Level V -
maintenance activities were performed using a non-approved
procedure (Report No. 50-341/85013). Two concerns were identi-
fled in the preventive maintenance (PM) program: (1) the
! current low rate of completion of scheduled PM Tasks and (2) the
potential for applying resources to lower priority PM tasks when
higher priority tasks or tasks of the same priority are overdue.
The licensee has established an 18 month calibration interval
for all calibrations not required by the Technical Specifica-
tions. The rationale for this decision was that if the interval
was too long, it would become apparent by faulty instrument
output and the calibration interval would be shortened. This
approach appears to be non-conservative and assumes an out-of-
calibration situation would be detected and corrected before any
safety impact resulted. Further review of the licensee's
program is planned to determine the adequacy of action,
j Modifications and corrective maintenance activities are being
conducted in accordance with program commitments and no items
'
1 of concern were identified. .
Maintenance is controlled with well stated and understood pro-
grams, although, as noted above, the PM program contains some
'
weaknesses. The staff is knowledgeable and well trained. #
Some understaffing is evident which has resulted in the low
completion rate of PM tasks and has resulted in some priority
work being postponed. Management attention in this area appears
to be weak as evidenced by the failure to evaluate or correct
the low rate of completion of PM tasks.
2. Conclusion
i
The licensee is rated Category 2 in this area. Insufficient
data base existed to establish a trend.
.
3. Board Recommendations
None. ;
i
15
__
-
..
'
.
I
H. Surveillance
1. Analysis
One inspection was conducted in this functional area by a
,
region based inspector. The inspection (50-341/85026(DRS)),
was performed to determine the adequacy of implementation of
the licensee's surveillance program. In addition, a review
of procedures was performed by the resident inspectors during
,
much of the assessment period.
Management attention and staffing appear adequate. The staff
is well trained and the program clearly defined and stated.
!
No violations were identified in this area.
2. Conclusion
i'
The licensee is rated Category 2 in this area. No data base
existed to estabitsh a trend.
3. Board Recommer,dations t
None. I
l
1. Analysis
, i
! One inspection was conducted in December 1984 and included
followup of licensee actions on previously identified items
relating to emergency preparedness and also observation and
evaluation of an assembly and accountability drill.
No violations were identified. Items examined and considered [
satisfactorily completed by the licensee included development
of a program for the surveillance, maintenance, and calibration
- of the meteorological measurement system, completion of the
Prompt Public Notification System to ensure that administrative
'
and physical means exist to alert the public of an emergency l
condition, a reevaluation of certain Emergency Action Levels
(EALs) to make them more objective to include quantitative ,
.
values where applicable, and an increased effort in training '
to incorporate reactor and containment conditions in Protectic..
Action Recommendations (PARS).
These open items were satisfactorily completed. This demon-
strated decision making at a level that ensures adequate
management attention. The technical issues which needed
resolution were closed in a timely manner. The licensee's
responsiveness to NRC initiative has been viable, generally
4
sound, and thorough.
16
_ . _ _ _ _ _._ ____ ___. _ _ _ _ , _ _ _ _ _ _ _ _ _ . _ - . _ . _ _ . _ _ . _ _ _ _ _
,
i !
-
, ..
- ;
! !
!
j Staffing has been ample. The quality of staffing has been well
1 demonstrated in the Emergency Preparedness Appraisal, the 1984 :
i Emergency Exercise, and various interchanges between the inspec-
I tors and the staff in the December 1984 inspection. Positions 1
i are identified and authoritin id responsibilities are well !
defined.
i !
i Overall the licensee has a well organized, proceduralized l
I training program which has proven effective. This includes a !
j matrix which identifies courses required for each of the !
positions in the emergency organization. l
1
'
2. Conclusion !
i
l The licensee is rated Category 1 in this area. Performance has
l remained the same during the assessment period,
t
i' 3. Board Recommendations
!
None
j J. Security ,
^
1. Analysis
1
l One special inspection and three routine preoperational inspec- f
- tions were conducted by regional based inspectors prior to
license issuance. One .gacial and one routine inspection were ,
l conducted subsequent to license issuance. The allegations l
1 reviewed during the special inspection conducted prior to t
j licensing involved alleged improprieties in the licensee's ,
i background screening program and were not substantiated. One [
Severity Level IV violation - Failure to adequately control r
access to a vital area - was identified during the post !
licensing special inspection and resulted in an enforcement l
conference being held. j
i :
! During the early part of the preoperational phase a number of !
deficiencies were noted in middle management's ability to ade- !
quately implement their program. Although remaining optimistic
i that systems would initially perform adequately, repeated (
! failures caused senior management to become directly involved. l
1 For example, although ample staff resources were available they
!' did not appear to be used effectively; some items were described
as being completed / closed when they were not; technical solu- l
- tions to ;.roblems such as certain door interlocking problems i
! were initially not solved; and excessive alarms were being !
! generated. Middle management was also very reluctant to remove ;
! certain unnecessary security equipment that was described in L
j published NRC guidance and identified as being possibly detri- ;
i mental to optimum plant safety. ,
i l
'
\
i !
17
I !
,
t
___-!
_ _ _ _ _ _ _ _ . . - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _-.
," .-
4
As a result of our inspection results and their own review,
senior licensee management became more actively involved in
the implementation and overview of the program. That activity
resulted in innovative and effective approaches, such as the
multi-disciplined committee that was established to address
system-related problems. It was only after that senior level
involvement did needed progress occur to implement the system.
Once begun the program was adequately implemented. l
'
l
Subsequent to license issuance, compliance with the security !
plan becomes mandatory. A violation of that plan was identified !
and reported by the li ensee shortly (32 days) thereafter. This
I single incident involved breakdowns in several fundamental j
security subsystems and was considered significant. It demon- ;
-I
strated deficiencies in vital area access controls, responses, I
j alarm station operations, first line supervisory support and i
,
guard training programs. It appeared that although proper l
attention had been oaid to complying with specific requirements, j
some performance objectives had been overlooked. The signifi- l
cance and corrective actions for the event were well addressed I
by the licensee during the enforcement conference. The tech- l
nical review, analysis and approach to resolving the problem
along with the status of the plant at the time mitigated the
significance of the event and enforcement actions. The actions
taken should prevent recurrence of the violation and better
ensure that performance objectives will be met. !
The licensee has expended considerable effort to complete j
needed upgrades of some security equipment and alleviate other l
marginally acceptable security practices such as removing !
i systems that were identified as possibly being detrimental to !
plant safety. Security management personnel have been success- I
j ful in reducing the turnover of security personnel by closely
t monitoring personnel actions and changes. This increated
monitoring appears to have had a beneficial effect on morale
and reduced turnover. Additional resources have been committed
to strengthen a segment of the security training that was weak i
, and contributed to the violaticq. Although difficulties were !
identified during the assessment period, senior corporate manage-
'
.
ment actions and involvement have resulted in acceptable levels i
of protection. l
i 2. Conclusion
The licensee is rated Category 2 in this area. Licensee per-
formance has remained essentially constant over the course of
this SALP assessment period. i
3. Board _ Recommendations
,
None.
.
<
18
._ _ _ __ _ _ _ _ _ _ _ . _ . - _ _ _ . _ _ . ._ _.
__ ,_ _ _ -- - _ . _ _
. .
.
K. Fueling
1. Analysis
j The licensee received an operating license for Fermi 2 on
March 20, 1985, and initial fueling commenced within ten hours
'
I
after license issuance. Fueling was completed on April 4, 1985.
This activity was observed on a three shift basis by the
resident and regional inspectors during fuel movement and no
items of noncompliance were identified. Delays which occurred
during fuiling resulted from those associated with the refueling
bridge. The licensee completed fueling in less than the sched-
uled time with no personnel errors.
1
l Licensee management was closely involved with the fueling acti-
'
vities and all issues which were brought to their attention
received quick resolution. Staffing, training, and qualifi-
cations were ample to support safe, efficient completion of
fueling activities. The licensee was responsive when the
inspectors identified minor concerns.
j 2. Conclusion
j The licensee is rated Category 1 in this area. The licensee
]
was not rated during the last SALP period.
l 3. Board Recommendations
T
'
None.
L. Quality programs and Administrative Controls Affecting Quality
_
1. Analysis
1
This functional area was inspected on a routine basis by the
j resident inspectors and during three inspections by region-based
personnel during the assessment period. The region-based inspec-
'
tions were performed to determine the adequacy of operational
,
Quality Assurance programs for startup activities, audits,
receipt, storage, and handling of materials, document control,
4
procurement, QA/QC administration, records, and handling of
i preoperational test program records. In addition, considerable
inspection effort was expended in evaluating licensee corrective
- actions for previously identified deficiencies and items of
i concern which were also documented in the reports noted above.
Two violations were identified in this area. One of these
was in the area of quality control: Severity Level IV (50-341/
84-65) - QC inspectors failed to execute an adequate inspection
of activities affecting quality,
i
1
19
i
I _ - -__ - - -__ _ -_ _____-__-_
-
. .
.
I
The other violation was identified in the procurement area:
Severity Level V (50-341//84-48-02) - failure to ensure t at
the source inspection procedures used by the Purchasing Inspec-
tion Division were approved by the Nuclear Quality Assurance
Department. This item did have potential significance, in that
deficiencies identified during source inspections may not have
been properly tracked and resolved. The licensee took prompt
,
and extensive corrective action and the item was closed during
{
the assessment period.
.
Two concerns were identified in the audit area. Failure to
track vendor audit findings and schedule vendor audits in '
cordance with approved procedures, was identified and
resolved during the assessment period.
j The relatively large percentage of overdue actions in response
to internal audit findings was also a concern. The licensee
has taken corrective action in this area and the item remains
to be reviewed. Both items were of minor safety significance.
No violations or items of concern were identified in the
remaining areas.
I
During these inspections, 44 NRC items were closed. Many of
these items were related to construction phase activities. The
promptness and extent of licensee corrective action in resolving
these items indicates adequate management involvement.
In summary, management has been deeply involved in the correc-
tion of quality related issues. Quality programs are well
defined and stated. This functional area is adequately staffed
by knowledgeable personnel.
]
2. Conclusion
The licensee is rated Category 2 in this area. While this is
the same rating as given in the last SALP period, the licensee's
j performance trend has improved.
3. Board Recommendations
4
NRC inspection activity in this area should remain the same with
emphasis on program implementation.
M. Licensing Activities
1. Analysis
The staff concluded on March 20, 1985, that the licensee had
satisfied all the requirements for issuance of a low power
. license. The Commission briefing for a full power Itcense
i was held on July 10, 1985.
'
.
20
.
.- . . -. - -.-.- -- . .
-_ - ._.
c
-
<
, ..
4
i
i The licensee's management demonstrated active participation
i in licensing activities and kept abreast of all current and
i anticipated licensing actions. The staff found consistent
i evidence of prior planning and assignment of priorities.
! However, the licensee's management at times demonstrated a
lack of understanding of staff policy. This tended to delay
the resolution of important matters such as fire protection.
'
The licensee's management and its staff demonstrated a sound
technical understanding of the issues involving licensing
actions. This continues to be the strongest element in the
licensee's performance.
- e
i The licensee has responded pronptly to staff requests for t
additional information in most cases. However, some documen-
i tation has been submitted in a tardy manner requiring an
. expedited staff review to maintain the licensing schedule.
! With some effort by the licensee in the areas of management
- control and responses to NRC initiatives and continued good
- performance in the other rating categories, an overall rating
j of above average could be achieved since the licensee's rating
,
is slightly better than a 2 and is trending up. The licensee '
i
'
received an overall rating of 2 in the last SALP evaltation by
NRR.
I r
i
1 2. Conclusion
J l
'
The licensee is rated Category 2 in this area.
f 3. Board Recommendation I
I
l The licensee should continue to address their licensing activity ,
- with an enhanced understanding of staff policy and positions and j
l attempt to submit all documentation in a timely fashion. l
l
- y
i i
1 !
i
i
f !
! !
> :
i
[
i [
] -
i
21 r
i r
l
I
-
..
.
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
For the first six months of the assessment period, Fermi 2 was con-
sidered to be in the construction /preoperational testing phases prior
to assuming any type of startup/ power operations. On March 20, 1985,
a low power operating licensed was issued by the NRC, and initial
fuel loading began approximately six hours later. At that time, all
systems that were required to support safe startup and operation of
the unit were operable. Fueling was completed with no significant
problems and ahead of schedule. Startup testing continued with
initial criticality occurring on June 21, 1985. For the remainder
of the assessment period, the unit has been operating at less than
5% power with the low power testing portion of the startup program
continuing.
B. Inspection Activities
Throughout the assessment period, NRC Region III conducted inspec-
tions to assess the readiness of Fermt 2 for power operations.
Included in this program were reviews of the plant fire protection
program; procedures; Technical Specifications; Final Safety Analysis
Report (FSAR); As-Built configuration comparisons; adequacy of
operating shifts; and adequacy of management and engineering support
activities. In addition, a team inspection was conducted at the end
of the assessment period to assess the readiness for operation of
each working department directly involved with the unit. These
included Maintenance, Radiation Protection, Operations, and
Surveillance groups.
22
}
.
..
.
TABLE 1
INSPECTICN ACTIVITY AND ENFORCEMENT
No. of Violations in Each Severity level
Functional Areas I II III IV V Deviations
A. Piping Systems
and Supports 1 1
8. Electrical Power
Supply / Distribution
and Instrumentation /
Control Systems 6
C. Fire Protection 2
D. Preoperational and
Startup Phase Testing 2
E. Plant Operations 2 2
F. Radiological Controls
G. Maintenance 1
H. Surveillance
J. Security 1
K. Fueling
L. Quality Programs and
Administrative Controls 1 1
M. Licensing Activities __ _ _
TOTALS 13 5 2
23
. _. ~. - . ._ ._. . - ~ _ . _ _ _ _
-
.
.' ..
l
.
C. Investigations and Allegations Review
!
Nine inspections were performed during the-assessment period to
review allegations. None of the findings were significant. No
., investigations were conducted during the assessment period.
l D. Escalated Enforcement Action
l None.
E. Management Conferences Held During Appraisal Period
- 1. Management Conferences
a. October 4, 1984, Glen Ellyn, IL. Meeting to discuss
Fermi's-radiation protection program status.
'
'
b. October 23, 1984, Fermi plant site. Meeting to discuss
- the status of the Fermi facility,
j c. October 31, 1984, Fermi plant site. Meeting and tour
regarding DECO's response to the CAT team findings and
j the status of plant readiness for fuel loading.
I
d. November 2, 1984, Bethesda, MD. Meeting to discuss
general topics.
1
- e. December 5, 1984, Glen Ellyn, IL. Meeting to discuss
4
concerns regarding as-built drawing discrepancies and
} safety-related instrumentation calibration and setpoint
'
selection. i
i -
j f. December 10, 1984, Glen Ellyn, IL. Meeting to discuss
j the design documentation control,. calibration of instru-
4
ments, and separation of redundant electrical channels.
,
,
g. December 12, 1984, Fermi plant site. Meeting to discuss !
operational readiness review.
h. December 13, 1984, Fermi plant site. Meeting and tour
,
with Commissioner Zech.
!
i. December 31, 1984, Glen Ellyn, IL. Meeting to discuss
'
as-built drawings.
J. January 3,1985, Glen Ellyn, IL. Meeting to discuss
i SALP.
k. February 3, 1985, Fermi plant site. Meeting to discuss
corrective action regarding as-built drawings.
t
'
24 i
,
, - _ _ . _ . _ . - _ - . -
...___ -_ ,,-.._. _. _ _ _ _ _ _ . . _ . - - . _ . _ , - _
-
..
.
1. April 4, 1985, Fermi plant site. Meeting to discuss NRC's
perspective on potential problem areas during startup and
testing. Also used to discuss NRC's inspection and
enforcement practices for operating reactors,
m. May 15, 1985, Fermi plant site. Meeting to discuss bi-
weekly visit to discuss full power licensing readiness
at Fermi.
n. May 21, 1985, Glen Ellyn, IL. Meeting to discuss
physical security findings.
2. Confirmation of Action Letters
None.
F. Review of Licensee Event Reports, Construction Deficiency Reports,
and 10 CFR 21 Reports Submitted by Licensee
1. 10 CFR 50.55(e) Reports
Eight 10 CFR 50.55(e) reports were generated from the Fermi
plant during the appraisal period. Six of the eight reports
have been resolved. Two reports remain unresolved from the
previous SALP period. The first deals with a potential design
deficiency in the buried portion of the fire protection system
and the second deals with an apparent design deficiency on the
RHR Reservoir.
2. 10 CFR 21
Five Part 21 reports were resolved for the Fermi plant during
the appraisal period. There are no unresolved items at this
time.
25
, - . . _ - . _ - _ , - ~_ ._ .- .
,.
. .
gs.n tscg UNITED STATES
- g
,,
NUCLEAR REGULATORY COMMISslON
,
[ Te( g REGION til
f
!
3 V E
799 ROOSEVELT ROAD
l, N " 8 cLEN ELLYN. ILLINOIS 60ln
gv f .
....-
,
JUN 281985
,
Docket No. 50-341
Detroit Edison Company :
ATTN: Dr. Wayne H. Jens i
Vice President
Nuclear Operations
2000 Second Avenue
l
Detroit, Michigan 48226 L
Gentlemen: l
4 ,
j Enclosed for your review, prior to our scheduled meeting of July 2,1985, is
,
the SALP Board Report (summary) for the Enrico Fermi Nuclear Station covering i
the period October 1,1984 through June 30, 1985. l
,
During the assessment period, your emphasis has shifted from construction to (:
- preoperational testing and operational readiness. With this shifting emphasis
'
I and considering your schedule for requesting full power authorization, we !
have evaluated your programs related to these areas and have included our l
- findings in this assessment report. ;
.
"
During this assessment period your regulatory perfomance at the Fermi station
was considered to be acceptable and showed an improving trend. You were rated i
Category 1 in 3 areas (Fueling, Emergency Preparedness, Preoperational and
Startup Testing), Category 2 in 9 areas, and Category 3 in one area. The !
Category 3 rating was in the area of fire protection and was primarily
based on management's failure to identify problems and effectuate timely !
resolution. The performance trend within the assessment period improved
i
in 3 areas, remained the same in 6 areas and has not declined in any of i
j the remaining areas trended. A trend could not be determined in 4 areas. ;
The enclosed SALP Board report is a brief sumary of the final SALP I
report which will be issued at a later date. This summary report j
includes all functional areas assessed during the SALP 6 period, your ,
ratings in each functional area, and a brief sumary of our findings used
in determining the associated ratings, i
t
While you will have sufficient opportunity to present your coments at L
the meeting on July 2,1985, you may also provide written coment within l
30 days after the meeting. We will evaluate any written comments and :
provide you with our conclusions relative to them. '
In accordance with Section 2.790 of the NRC's " Rules of Practice". Part ;
,
2, Title 10, Code of Federal Regulations, a copy of this letter and the l
SALP Sumary Report will be placed in the NRC's Public Document Room. ;
4
[
,
i
Y f &,$
u r r i s- w my
- -
. - _ _- . _ _ , -. - - .. - . - - , - - - - - - - _ - -__ - . - _ .
- - .
.
,
Detroit Edison Company 2 . ,,
ho reply to this letter is required at this time; however, should you have any
, questions concerning the SALP Report, we would be pleased to discuss them with
- you.
Sincerely,
i crictnal signed by
- Jaxs G. KePpler
j
-
James G. Keppler
Regional Administrator
Enclosure: SALP Summary Report
No. 50-341/85027
'
cc w/ enclosure:
' L. P. Bregni, Licensing
Engineer
) P. A. Marquardt, Corporate
Legal Department
i
DMB/ Document Control Desk (RIDS)
, Resident Inspector, RIII
- Ronald C.nllen, Michigan
Public Service Comission
i
I
Harry H. Voigt, Esq.
Nuclear facilities and
- Enviror. mental Monitoring
Section
!
J. M. Taylor, Director, IE
I
H. R. Denton, Director, NRR
i Regional Administrators
RI, RII, RIV, RV
i N. J. Palladino, Chairman
i J. K. Asselstine, Comissioner
i T. M. Roberts, Comissioner
L. W. Zech, Comissioner
NRR Project Manager
H. L. Thompson, NRR
J. Axelrad. IE
,
RI!! PRR
'
RIII SGA
State Liaison Officer, State of
,
6
l l
.
i
_________ - - - - - - - - - - - - - - - - - - - - - - - -
'
'
.
.
T
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COPFISSION
REGION III
.
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-341/85027
Inspection Report No.
Detroit Edison Company
Name of Licensec
l
Fermi 2
Name of Facility
October 1, 19_84 throuch lune 30,,1985
Assessment Period
P
,
,C43- ,, e m
w 7 7,w
-
-
y/a --
c /, -
__
.-
,
[
.
I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) progran is
an integrated NRC staff effort to collect available observations and
data on a periodic basis and to evaluate licensee perfornance based
upon this information. SALP is supplemental to nomal regulatory
processes used to ensure compliance to NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational
basis for allocating NRC resources and to provide meaningful guidance
to the licensee's management to promote quality and safety of plant
construction and operation.
An NRC SALP Board, composed of staff members listed below, met on
June 27, 1985, to review the collection of performance observations
and data to assess the licensee's performance in accordance with the
guidance in NRC Manual Chapter 0516 " Systematic Assessment of
Licensee Performance." A sumary of the guidance and evaluation
criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensce's safety
performance at Fermi Unit 2 for the period October 1,1984, through
June 30, 1985.
SALP Board for Fermi 2:
Name Title
J. A. Hind Director, Division of Radiation Safety
and Safeguards (DRSS)
R. L. Spessard Director, Division of Reactor iafety (DRS)
C. E. Norelius Director, Division of Reactor Projects (DRP)
C. J. Paperiello Chief Emergency Preparedness and Radiation
Safety Branch
L. A. Reyes Chief, Operations Branch, DRS
N. J. Chrissotimos Chief, Reactor Projects Section ID
J. R. Creed Chief, Safeguards Section
M. A. Ring Chief, Test Programs Section
M. P. Phillips Chief Energency Preparedness Section
D. H. Danielson Chief, Materials Section, DRS
T. Madeda Security Inspector, DRSS
S. G. DuPont Reactor Inspector, TPS
S. Stasek Project inspector, Reactor Projects
Section 10
Z. Falevits Reactor Inspector, DRS
R. Hasse Reactor Inspector, DPS
M. D. Lynch Licensing Project Manager, NRP
?
__ . . . - - - _ _ . . - - - _ _ . .-_-...- - - - . -. - - ._ -- . . . -
t .
-
j. .
1
!* i
,
II. CRITERIA
t
i The licensee's perfornance is assessed in selected functional areas ;
depending whether the facility is in a construction, pre-operational
'
j
!
or operating phase. Each functional area normally represents areas !
! significant to nuclear safety and the environment, and are normal j
programatic areas. Some functional areas may not be assessed because
'
j
i of little or no licensee activities or lack of meaningful observations.
l Special areas may be added to highlight significant observations.
!
l One or more of the following evaluation criteria were used to assess
{;
each functional area. ,~
j 1. Management involvement in assuring quality !
2. Approach to resolution of technical issues from a safety standpoint :
1 3. Responsiveness to NRC initiatives
i
'
j 4 Enforcement history
l 5. Reporting and analysis of reportable events l
l !
'
l 6. Staffing (including naragement)
- i
'
I
7. Training effectiveness and qualification.
j However, the SALP Board is not limited to these criteria and others
j may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated ,
is classified into one of three perforriance categories. The definition
of these performance categories is:
} Category 1: Reduced NRC attention may be appropriate. Licensee
1
nanagement attention and involvement are aggressive and oriented '
toward nuclear safetyt licensee resources are ample and effectively
)l
i
used so that a high level of performance with respect to operational
safety or construction is being achieved,
i
4
Category 2: NRC attention should be maintained at normal levels. *
! Licensee management attention and involvement are evident and are .
'
1 concerned with nuclear safety; licensee resources are adequate and
-
are reasonably effective such that satisfactory performance with
respect to operational safety or construction is being achieved.
f
l ,
1 Category 3: Both NRC and licensee attention should be increased. -
! Licensee management attention or involvement is acceptable and
i considers nuciear safety, but weaknesses are evident; licensee
resources appear to be strained or not effectively used so that
minimally satisfactory performance with respect to operational
safety or construction is being achieved. l
I
3
i .-_._, _ ,.- _ _ .. - _ __. - ~. - ,,_ _ _. . -..__ ___ __, , , _ . . _ _ _ - _ - _ ~ . _ . _ - _ , _ -
. .- .-_ . _ . . . _ - . -. . - . - .- - -
-
..
.. .
1
i
{
'
Trend: The SALP Board has also categorized the performance trend
i in each functional area rated over the course of the SALP assessment
i period. The categorization describes the general or prevailing
j tendency (the performance gradient) during the SALP period. The
i performance trends are defined as follows:
3
I Improved: Licensee perfornance has generally improved over the
course of the SALP assessment period. '
Same: Licensee perfornance has renained essentially constant
i
over the course of the SALP assessment period.
I
,
'
! Declined: Licensee performance has generally declined over the
course of the SALP assessment period.
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III. SUMMARY OF RESULTS
' Overall, the licensee's performance was found to be acceptable cnd
showed an improving trend. The licensee was found to have aggressive
'
management attention and a high level of performance in the areas of
Emergency Preparedness, Fueling, and Preoperational and Startup Phase
,
Testing. Performance in the Fire Protection area was found to need
'
increased management attention as well as maintenance of the current
increased NRC staff attention during subsequent inspections.
Rating Last Rating This
Functional Area Period Period Trend
A. Piping Systems
- and Supports 2 2 Same
B. Electrical Power
Supply / Distribution
i and Instrumentation /
j Control Systems 3 2 Improved
C. Fire Protection 3 3 Same
1
0. Preoperational and
Startup Phase Testing 2 1 Improved
E. Plant Operations NR 2 NR
< F. Radiological Controls 2 2 Same
i G. Maintenance NR 2 NR
H. Surveillance NR 2 NR
I. Emergency Preparedness 1 1 Same
J. Security 2 2 Same
Fueling
'
K. NR 1 NR
l L. Quality Programs and
+
Administrative Controls 2 2 Improved
,
M. Licensing Activities 2 2 Same
} *NR = not rated or not rated separately,
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_-. . . .- _ -
.- . -
- _ _ _ _
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PIPING SYSTEMS AND SUPPORTS
CATEGORY 2 PERFORMANCE
TREND WITHIN SALP PERIOD 'SAME
- Inspections focussed on closecut of items.
Two Violations:
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. Nonrepetitive..
. Not Programmatic.
- Management Controls, Adequate.
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- Records Complete and Well Maintained.
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- Know!cdgeable Staff.
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ELECTRICAL POWER SUPPLY AND DISTRIBUTION
AND
INSTRUMENTATION / CONTROL SYSTEMS
CATEGORY 2 PERFORMANCE
TREND WITHIN SALP PERIOD IMPROVED
- Major inspection effort / utility effort.
- Six Violations.
- * Hardware and drawing changes required.
- 3rawing control improved.
- Comprehensive corrective action.
.
- --
. - _ . -____ _ _ _
-
..
..
.
FIRE PROTECTION
CATEGORY 3 PERFORMANCE
'
TREND WITHIN SALP PERIOD SAME
- Acceptable Program Implemented.
- Adequate Plant Systems and Procedures.
'
- Adequately Trained Operations Personnel
- Major Management Concerns on 3roblem
Identification.
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PRE 0PERATIONAL AND STARTUP TESTING !
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CATEGORY 1 PERFORMANCE l
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TREND WITHIN SALP PERIOD IMPROVED
- Extensive NRC Involvement. ;
- Early Problems Resolved.
- Progressive Improvement.
- Aggressive Management Initiatives.
- Two minor violations concerning
leak rate testing. l
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- . , _ _ - . - . _ . . -- - - - _ _ _ _ _ - - ,
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PLANT OPERATIONS
CATEGORY 2 PERFORMANCE
NO TREND - FIRST ASSESSMENT
,
- Four Violations.
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- Seventeen L Rs.
- NRC License Pass Rate High.
- Operational Readiness inspection.
- Good Management Attention.
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RADIOLOGICAL CONTROLS :
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CATEGORY 2 PERFORMANCE
TREND WITHIN SALP PERIOD SAME
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- No Violations. !
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- Management involvement Satisfactory.
- Responsiveness to NRC Issues Satisfactory.
- Radwaste Systems Status Acceptable.
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. . _ _ _
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MAINTENANCE
CATEGORY 2 PERFORMANCE
NO TREND - FIRST ASSESSMENT
- One Violation Identified.
- Maintenance Program Well Defined.
- Corrective Maintenance Activities Adequate.
- Preventative Maintenance Concerns:
. Low Completion Rate.
. Prioritization.
. Management Attention. !
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.- - _ _ - -
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SURVEILLANCE :
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CATEGORY 2 PERFORMANCE
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NO TREND - FIRST ASSESSMENT ,
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- Management Attention Acceptable. l
- Staffing Adequate.
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- Surveillance Walk-throughs. !
- No Violations. ;
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- - - - _ . -- .. -_ . _ - - .
. _- ..
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CATEGORY 1 PERFORMANCE
TREND WITHIN SALP PERIOD SAME
- No Violations.
- Demonstrated Decision Making.
- Well Qualified Staff.
- Program Well Defined.
- Responsive to NRC Initiatives.
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SECURITY
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CATEGORY 2 PERFORMANCE j
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TREND WITHIN SALP PERIOD SAME
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- Senior Management Actively involved.
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- Middle Management Deficiencies.
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. Program Implementation. l
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. Technical Solutions.
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- Security Event - Enforcement Conference
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. Management Aggressiveness. f
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- - - _ _
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. . - - - . _
-
. -
. _
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6
FUELING
CATEGORY 1 PERFORMANCE
'
NO TREND -
FIRST ASSESSMENT
- Management involvement.
- No Personnel Error.
- No Violations.
- Conservative Approach.
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_
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QUAUTY PROGRAWS AND ADMINIS1RATIVE CONTROLS AFFECTING QUAUTY I
CATEGORY 2 PERFORMANCE
TREND WITHIN SALP PERIOD IMPROVED
- Program Well Defined.
'
- * Adequate Staffing.
- Responsive to NRC concerns.
'
- Two Minor Violations.
- Backlog of Internal Audit Findings.
!
.._ . _. . .. . . - _ - .
. _- ..
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LICENSING ACTIVITIES
CATEGORY 2 PERFORMANCE
TREND WITHIN SALP PERIOD SAME
- Active Management Participation.
- Prior 3lanning.
- Technical Understanding of Issues.
- nconsistent Information Exchange.
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TABLE 1
No. of Violations in Each Severity Level
Functional Area I II III IV V Deviations
Operations 2 2
Radiological-Controls ;
!
Maintenance 1
Surveillance
Fire Protection 2 ,
i
Security 1 j
Fueling ._ l
Piping Systems l
and Supports 1 1 !
Electrical Power
Supply / Distribution
and Instrumentation /
Control Systems 6' -
Preoperational and !
Startup Phase Testing 2 -
Quality Programs and
Administrative Controls 1 1 !
'
Licensing Activities
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19
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