IR 05000320/2010031

Insp Rept 50-341/85-42 on 851001-1130.Violation Noted: Failure to Submit LERs within 30 Days After Discovery During 850320-1031

ML20136F414
Person / Time
Site:	Fermi, Three Mile Island
Issue date:	12/30/1985
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136F377	List: IR 05000320/2010031 IR 05000341/1985042 ML20136F404
References
50-341-85-42, NUDOCS 8601070372
Download: ML20136F414 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/85042(DRP)

Docket No. 50-341 License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Fermi 2 Inspection At: Fermi Site, Newport, MI Inspection Conducted: October 1 through Noveraber 30, 1985 Inspectors: P. M. Byron M. E. Par!.er 8,lAJ

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Approved By: . C. Wr t', Chief Reactor Projects Section 2C

/2kD Date Inspection Summary Inspection on October 1 through November 30, 1985 (Report No. 50-341/85C42(DRP))

Areas Inspected: Routine unannounced inspection by resident inspectors of regional requests, meetings with local officials, licensee event followup, operational safety, maintenance, surveillance, report review, plant trips, independent inspection, radiological emergency response drill, facility modifications and design, design changes and modifications. The inspection involved a total of 297 inspector hours onsite by two NRC inspectors, including 52 inspector-hours onsite during off-shift Results: Of the 12 areas inspected, no violations or deviations were identified in 11 areas. Within the remaining area one violation was identified (Paragraph 4, failure to submit licensee event reports within thirty days) which had no compact on safet PDR ADOCK 05000341 G PDR

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DETAILS Persons Contacted

• F. Agosti, Manager, Nuclear Operations

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S. Booker, Assistant Maintenance Engineer L'. Bregni, Compliance Engineer

• J. Conen, Licensing Engineer

• J. DuBay, Director, Computer Service & Information Systems R. Eberhardt, Rad-Chem Engineer P._Fessler, Maintenance Engineer

• E. Griffing, Assistant Manager, Regulation & Compliance

• W.~ Jens, Vice-President, Nuclear Operations W. Hastings, Director, Nuclear Security

• J. Leman, Superintendent, Maintenance and Modification Engineer

• L. Lessor, Consultant to the Assistant Manager, Nuclear Production

• R. Lenart, Assistant Manager, Nuclear Production R. Mays, Outage Management Engineer

* Miller, Supervisor, Operational Assurance S. Noetzel, Assistant Manager, Nuclear Engineering

, J. Nyquist, Supervisor, Independent Safety Engineering Group T. O'Keefe, Supervisor, Mechanical Civil Engineering

• G. Overbeck, Assistant Plant Superintendent, Startup J. Plona, Technical Engineer E. Preston, Operations Engineer W. Ripley, Assistant Operations Engineer - Administrative C. P. Sexauer, Nuclear Production Administrator G. Trahey, Director, Quality Assurance

• R. Wooley, Acting Supervisor, Licensing

• Denotes those who attended the exit meeting The inspectors also interviewed others of the licensee's staff during this inspectio . Followup on Regional Requests (92705B)

SAFETEAM The inspectors reviewed on October 18, 1985, the concerns contained in

53 SAFETEAM interviews made since February 5, 1985. Three items of 4 potential wrongdoing were noted during the review. These items had been previously transmitted to Region III and will be documented in subsequent inspection reports pending inspector review of the licensee's investigatio The inspectors also noted a concern (No. 694 dated September 26,1985)

which described the failure of Nuclear Engineering to perform a seismic analysis on engineering changes. SAFETEAM procedures require that the resident inspector be informed by memorandum of all wrongdoing concerns within five days of receipt. Neither the SAFETEAM nor the licensee has t

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formally notified the resident inspectors of this concern to dat The inspectors have determined that senior nuclear operations management was made aware of this concern on September 30, 1985. The inspectors were unaware of this concern until their review of October 18, 198 Subsequently the inspectors were made aware that the equipment qualification (EQ) review had not been performed. An additional review of concern No. 694 revealed that the EQ concern had been adde The licensee has not formally informed the inspectors of these issues which is considered to be an unresolved item (341/85042-01(DRP)). The licensee subsequently performed an EQ review and no problems were identifie Region III inspectors reviewed the licensee's action This will be documented in Inspection Report No. 50-341/8505 The licensee is currently investigating the SAFETEAM concern relating to seismic reviews and plans to perform a 100% review of all documents which may be affected. Region III plans to review the licensee's action This concern and the results of the various inspections will be documented in subsequent report The review also included the responses of approximately 45 interview The inspectors consider that all but one of the responses adequately addressed the concerns. The licensee was informed of the inspectors concern and stated that a revised response would be issue . Meetings with Local Officials (94600)

The Regional Administrator, Region III, with members of his staff met with members of the Monroe County Board of Commissioners, including the

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Chairman, and members of their staff on October 10, 1985. The purpose of

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the meeting was to brief the Commissioners on recent events at Fermi 2 and other matters of common interest. The county took the opportunity to give a tour of their new Emergency Response Center to the Regional Administrato . Licensee Event Followup (94700)

The licensee has issued 67 Licensee Event Reports (LERS) from March 20 through October 31, 1985. The inspectors have only been able to close out two of these. The inspectors' review of the LERs has revealed several areas of weakness in the licensee's program. Discussions with the licensee demonstrated that they do not have an effective tracking system and are unable to status LERs. Unless the licensee is able to status LERs, similar problems to those experienced while closing out NRC open items prior to licensing will be encountered. The licensee was informed of the concern and stated that they will develop a system to track the status of LER The inspectors consider the licensee's safety evaluation to be less than adequate. LER No.85-060 " Primary Containment Valve Left Open" dated October 11, 1985, is used as an example. The licensee found a primary containment monitoring valve (T50-F071A) to be open and uncapped on

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September 2, 1985. The valve had been open and uncapped since at least i

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June 20, 1985. While the valve was open primary containment was breached. The LER contained a three page narrative sequence of events and a short safety evaluation which stated:

"The actual safety significance of the event is low primarily because the fission product inventory of the reactor is minimal since power was limited to five percent over the entire perio The pathway size was small (3/4 inch line) and no events occurred which required the primary containment boundary for protection."

The inspectors consider that the above statement does not constitute a safety evaluation and have expressed their concern to the license The licensee stated that LER No.85-060 would be revised. This is not an isolated case and the licensee sho'ld take steps to strengthen the evaluation proces CFR 50.73(a)(1) requires that the licensee submit an LER for reportable events within thirty days of discovery. The licensee has failed to submit 16 LERs (24%) within the thirty-day requirement. The discrepancies have ranged from 1 to 76 days. This is considered to be a violation of 10 CFR 50.73(a)(1) (341/85042-02(DRP)).

The inspectors consider the licensee's LER program to be less than adequate and the licensee must take the necessary steps to strengthen their program. This is considered an Open Item (341/85042-03(DRP)). Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period from October 1 to November 30, 1985. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the reactor building and turbine building were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the

' station security pla The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection, the inspectors walked down the accessible portions of the Core Spray and Reactor Heat Removal systems to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could -

degrade performance; and verified that instrumentation was properly valved, functioning, and calibrate l l

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The inspectors also witnessed portions of the radioactive waste system controls associated with radwaste shipments and barrelin These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure No violations or deviations were identified in this are . Monthly Maintenance Observation (62703)

Station maintenance activities of safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activity was observed:

• Emergency Diesel Generator #13 Repair No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The inspectors observed surveillance testing required by technical specifications and verified that; testing was performed in accordance with adequata procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed portions of the following test activities:

• Twenty-four hour Run and Load Test of Emergency Diesel Generator #14

• Loss of Offsite Power Test on Emergency Diesel Generator #14

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s On November 13, 1985, the licensee was performing a Technical Specification required surveillance, 24-hour run test, on emergency diesel generator No. 13 when an unusual noise and vibration was observe The operator manually tripped the diesel. The plant was in cold shutdown in an outage for maintenance and installation of NRC required equipment including a remote shutdown pane Initial inspection of the diesel generator indicated damage to the connecting rod bearings for the upper crankshaft and to the No. 3 cylinder liner and upper piston skir The root cause of the failure is being investigated by a special licensee task force. The NRC has also sent representatives from NRR, Region III, and NRC consultant No violations or deviations were identified in this are . Independent Inspection (92706)

Control of Paperwork The licensee has historically had difficulty in controlling paperwor The licensee has not been successful in addressing these issues as they continue to have difficulty as the following examples will illustrat The licensee was requested by the inspectors in June 1985 to provide a computer printout of the NRC people badged at Fermi 2, The licensee provided a printout from security and from training. The training printout lists the individual and his requalification date The lists did not agree and the inspectors informed the licensee of this finding. 'The licensee stated that the problem would be corrected. The inspectors again requested the same two list The licensee provided the security printout dated 11-27-85 of NRC inspectors badged at Fermi and the training printout of requalification dates dated 11-28-85. The lists still do not agre In addition the training list is only current as of September 30, 1985. The printout supplied by training supposedly reflects the training of each individual at Fermi yet the data base is approximately two months out of dat The security printout revealed that a former NRC employee was badged at Fermi as of November 27, 1985. Yet a letter dated July 9, 1985, was written to the licensee requesting that this individual be deleted from the access list. The NRC sent a revised access list to the licensee on November 1, 1985. The deleted individual plus four NRC contract personnel were not on the access list. The licensee issued an NRC access list dated November 7,1985, and the five individuals were not on the licensee's list. However, all five individuals were still badged at Fermi 2 as of on November 27, 198 Region III security specialists are reviewing the licensee's ac. cess control and additional details will be documented in a subsequent repor L ____ ___

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$ The licensee issued Engineering Design Package (EDP) No. 1970 dated i- February 18, 1985, to add eight test connection cutoff valves. Four

. PN-21's (work orders) were issued to perform the work. The work was completed approximately June 19, 1985. The EDP and the four PN-21's remain open. The, licensee has been unable to explain to the inspectors rhy these documents are not closed out five months after

. the work had been complete The-licensee performed an audit of open PN-21's (those signed on by the Nuclear Shift Supervisor to be worked). The audit results revealed that of the 406 open PN-21's, 198 had been completed. The inspectors have requested the licensee determine why 198 PN-21's were classified as open when in actuality they were closed and to age these items. The licensee informed the inspectors that 50% of the 198 were older than three months. The licensee, however, has not identified the cause of this problem. The corrective action to preclude the problem is to perform a daily audit. The inspectors do not believe that this short-term corrective action is adequate.

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No violations or deviations were identified in this are . - Radiological Emergency Response Drill (82301)

The licensee performed the required radiological emergency response drill

on October 2, 1985. The drill was monitored by Region III specialists and is documented in Inspection Report 50-341/85041(DRSS).

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No violations or deviations were identified in this are . Facility Modifications (37701)

Facility Modifications that require prior review and approval from the Commission pursuant to 10 CFR 50.59 of safety-related systems and components listed below were observed to ascertain that they were completed in conformance with requirements in the facility license, Technical Specifications (TS), 10 CFR and applicable codes and standards to which the facility was buil The.following items were considered during the review: The new or modified systems on components were installed in accordance with approved designs, new or revised procedures relating to the modification were completed and approved in accordance with TS requirements, operator training programs were revised in a reasonable time frame consistent with implementation of the modification or design change, review of completed test records and as-built drawings were revised to reflect the modification or design change, and that control room drawings were i

revised prior to startup.

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The following facility modifications were reviewed:

• Remote Shutdown Pannel - 3L

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• T50 Containment Monitoring System - Hydrogen /0xygen Monitoring Subsystem

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Engineering Design Package (EDP) 1422 implemented the replacement of the environmentally unqualified H2 /02 Delphi System with the qualified Exo-sensors system which involved the elimination of the high-flow sample pump and modification of the main loop line. This modification was performed on redundant systems Division I/ Division I Engineering Design Package (EDP) 1702 implemented the installation of the alternate shutdown panel, for controlling plant operations in the ev u t of a fire in certain identified zones, including the control roo During this review the inspectors walked down P0M Procedure 20.000.18,

" Control of the Plant from the Dedicated Shutdown Pannel," to verify the adequacy of the procedure. The licensee has submitted a Technical Specification Amendment request concerning the 3L panel and is awaiting NRR review. See Inspection Report 50-341/85050 for further information concerning the Alternate Shutdown Pane No violations or deviations were identified in the review of this program are . Design, Design Changes, and Modifications (37700)

Design changes and modifications that are determined by the licensee to not require approval by the NRC are in conformance with the requirements of the Technical Specifications and 10 CFR 50.59. The following items were considered during the review: changes had been reviewed and approved in accordance with 10 CFR 50.59 and that the reviews were technically adequate, design changes reviewed and approved in accordance with TS and established QA/QC controls, design changes were controlled by established procedures, activities were conducted in accordance with appropriate specifications, drawings, and other requirements, testing of modification were conducted in accordance with technically adeouate and approved procedures and appropriate controls were implemented during installation of the modification The following design changes and modifications were reviewed:

• Main Steam Bypass Line Replacement

• Limitorque Operator Changeout No violations or deviations were identified in this are . Report Review (90713)

During the inspection period, the inspector reviewed the licensee's Monthly Operating Report for October 1985. The inspector ccnfirmed that the information provided met the requirements of Technical Specification 6.6.A.3 and Regulatory Guide 1.1 No violations or deviations were identified in this are . .

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1 Plant Trips (93702)

Following the plant trips on October 1 and October 11, 1985, the inspector ascertained the status of the reactor and safety systems by observation of control room indicators and discussions with licensee personnel concerning plant parameters, emergency system status and reactor coolant chemistry. The inspectors verified the establishment of proper communications and reviewed the corrective actions taken by the license All systems responded as expected, and the plant was returned to operation on October 3, 1985. At the time of the plant trip on October 11, 1985, the licensee was in a plant shutdown for a planned outag Following the plant trip, the licensee proceeded into the outag No violations or deviations were identified in this are . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot An open item disclosed during the ins:;*ction is discussed in Paragraph . Unresolved Itus Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

on November 4 and 22, 1985, and informally throughout the inspection period and summarized the scope and findings of the inspection activitie The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary. The licensee acknowledged the findings of the inspectio k

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