IR 05000341/1982016
| ML20028A126 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/25/1982 |
| From: | Jackiw I, Reimann F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028A121 | List: |
| References | |
| 50-341-82-16, NUDOCS 8211160452 | |
| Download: ML20028A126 (11) | |
Text
___ -___-_ _
__ _ _ _- _ _ _ ______ ---.
.-
,
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/82-16(DETP)
Docket.No. 50-341 License No. CPPR-87 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48224 Facility Name: Enrico Fermi Nuclear Power Plant, Unit 2 Inspection At: Enrico Fermi Site, Monroe, MI Inspect n Co u.ed - September 27-30, 1982
.
f! '
f-
.se cerfMr In ector:
. W. Reimann
/O-f12 M Approved By: [N.Jekiw, Chief
/8 O Yb Rest P ograms Section Inspection Summary Inspection on September 27-30, 1982 (Report No. 50-341/82-16(DETP))
Areas Inspected: Routine safety inspection of preoperational test pro-cedures, construction testing (CAIO), preoperational test implementation, plant tours to verify that equipment and plant conditions meet program requirements to support testing, jurisdictional tagging controls,'and testing personnel qualification verification. The inspection involved 30 inspector-hours onsite by one NRC inspector including 9 inspector-hours onsite during off-shifts.
Results: Of the six areas inspected, no items of noncompliance ware identified.
,
L f
s M
f'211160452 821028 PDR ADOCK 05000341
,
,.
_,
-
._ _..
.
__.
.,.
[
.
DETAILS 1.
Persons Contacted
- T.
A. Alessi, Director, Project QA
- E. H. Newton, Supervisor, Operational Assurance
- M. A. Michalek, Superintendent, SCO
- A. Godoshian, Director, System Completion
- S. H. Noetzel,' Site Manager
- T.
L. Hintun, Site Operations Manager, General Electric
- J. R. Icard, Startup Assurance Engineer
- T.
S. Nickelson, Startup Director
- W. R. Holland, Assistant Vice President and Nuclear Operations Manager
- H. O. Arora, Startup Engineer
- D.
H. Elliott, Senior Engineer, Maintenance
- L. J. Trapp, Maintenance Engineer
- G. M. Trahey, Assistant Director, Project QA
- F. E. Agosti, Assistant Manager Nuclear Operations - Startup
- L.
B. Collins, Administrative Engineer, Startup
,
R. Willems, NSSS Startup Test Engineer R. Lemberger, NSSS Stactup Test Engineer J. Nyquist, Technical Staff Engineer
- Denotes those~ attending the exit meeting held on September 30,.1982.
The inspector interviewed several menbers of the licensee's startup, chemistry, and maintenance groups in addition to those listed above.
2.
Licensee Action on Previous Inspection' Findings (0 pen) Open Item (341/82-13-02, 03, and 04):
Standby Liquid Control System. The inspector interviewed the individual responsible for the followup on the items identified in Inspection Report No. 50-341/82-13, which affect the Standby Liquid Control System preoperational test.
Action was not completed in regard to the items. An additional example of this noncompliance is discussed in Paragraph 4 of this report.
(0 pen) Open Item (341/82-13-05):
Plant Housekeeping. The inspector noted that general cleanliness and housekeeping had shown improvement in the two weeks since the previous inspection. The licensee informed the inspector that the contractor individual responsible for adminis-
.tering housekeeping controls had been replaced, and that increased j
attention and improved management controls are being used to improve
'
cleanliness conditions. This item is'also discussed in Paragraphs 6 and 7.
i.,
y (0 pen) Open Item (341/82-13-01): Equipment Jurisdictional and Status Controls.
Licensee controls were further reviewed. Findings are discussed in Paragraphs 6, 7, and 11 of this report. The licensee has requested a meeting during the next inspection to resolve the inspector concerns.
.
4,
h
i i
)
_. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ - _ _ _
__ _
_ _
-
. _ -
_ - _ _ _ _ _ _ _.. _ _ _ _ _ _ - _ _ _ _ _.
_ _ _ _
c
'l
,
b
!
.
,
', <
,
y/ ;<'
4-
,
f
')
'
e 3.
Preoperational Test Program Status ([N
,
The'lidensee informed the ; inspector, that of the 92 preoperational f-test procedures scheduled for Unit 2, one is completed and turned over
to operations (TBCCW), five are completed and require final review
.
i by Nuclear Production for' acceptance, and sixteen are currentl'y in progress.
/
,
4.
--.iled Test Procedure Review Deta
,
The inspector conducted a detailed review of the approved procedure for Type C testing of Primary Containment Penetrations (PRET.T2306.001, Revision 0) which is approved and currently being implemented. Numerous concerns relating to various portions of the procedure were identified and discussed with the licensee, including:
Thrde different test devices are utilized in the procedures (gas a.
inflow, gas outflow, and water inflow). The procedure and data sheets for using the outflow analyzer for recording acceptance data-does not, however, provide step by step operating instruc-tions for gas outflow or water inflow test equipment.
N.
Criteria for accuracy, repeatability, and' calibration' frequency were not addressed for gas outflow and water test equipment.
Traceable calibrationsstahdards were not available for gas outflow c.
or water test devices..
d.
The test engineer is given the option of using gas inflow or outflow test methods at his discretion. This is considered unacceptable because no review or other assurance is provided
~
.to demonstrate that, for the outflow test; all penetration leakage will be measured through the outflow measuring device.
The lack of controls described in a.,
b.,
and c. above also
,
affect the acceptability of the outflow test results. The
~)
test engineer stated that the original intention of the outflow
.
analyzer was to use it for identification of leaking salves s
only.
It was agreed that (1) if the procedure were revised to
,
'
i
. prevent use of the outflow equipment for collecting acceptance
..
,
' data,, the concerns of a., b., and c. above could be disregarded, and (2) if the outflow analyzer is to be used to collect accept-
>
, ance criteria, the; concerns of a.,
b.,
c., and this paragraph ~
' ' shall be resolved by procedural revisions, e.
The formula for correcting gas flow results to standard conditions could not be verified using applicable regulations, standards, or documents referenced in the procedure; nor could the procedure preparer justify the formula. The licensee agreed to provide an analysis to justify the formula used.
I L
f
(
i
8
-
.
I f.
Examples were found where the testing commitments and justifi-cations for test method exemptions contained in Table 6.2.2 of the FSAR did not' reflect adequate analyses as required by the regulations, or did not address the actual design of plant
,
equipment.
Examples include:
(1) Justification for testing valves in the reverso direction (opposite'of the direction of post LOCA Icakage flow) is given as " installed configuration is not amenable to forward testing." No method of demonstrating that the reverse test
.,.
is conservative.with regard to the actual post LOCA leakage is provided. This concern is especially applicable to butterfly type valves because of the method by which they seat.
(2) Table 6.2.2 identifies stop check valves as simple globe
,
.j valves, and reverse tests them in the stop valve mode.
<,
The valve must_ function as a check mode during post LOCA conditions. Justification showing that reverse testing
'
is conservative, or a change in method is required.
S (3) Not conducting a leak test of the Control Rod Drive Hydraulic System Insert / Withdraw piping is justified by the existance of a check valve inside of the containment
,
(the scram ball check valve in the drive mechanism), and the solenoid operated directional control valves outside
,
containment (normally closed following an accident). This justification is considered unacceptalbe because (1) the
<
i
.f ball check valve is designed to operate in the opposite flow direction of that required to prevent post LOCA flow, and (2) the solenoid operated directional control valves are bypassed during post L3CA conditions by the scram valves, which are normally open during post LOCA conditions.
(4) Table 6.2.2 of the FSAR provides for testing numerous penetration flow paths with water rather than air. The procedure uses a water type test for 60 of the 219 valves to be Type C ta ted.
Although the concept of testing with water has been accepted by the NRC at other similar facilities, and such testing is allowed by 10 CFR 50, Appendix J, no justification or analysis is provided to demonstrate that the criteria prerequisite to allowing this gas test alter-native is provided (such as demonstration that a minimum 30 day water seal at greater than post accident containment pressure is provided for each water tested valve).
Additionally, no record of an acceptable analysis is pro-vided which considers the contribution of suppression pool water leaked through the vater tested valves to the post accident dose rate calculations which demonstrate compliance with 10 CFR 100.
,
k
.
g.
The procedure acceptance criteria are considered unacceptable:
(1) Allowable leakage for the Main Steam Line Isolation Valves-(MSLIVs) is defined as < 100 scfm for the four steam-line penetrations. The standard BWR technical specification (applicable to Fermi 2) is that leakage must be < 25 scfm for any valve.
(2) No acceptance criteria are provided for. valves tested'by the water test method (either per valve or total).
The inspector notes that Inspection Report No. 50-341/82-13.
contains a citation for inadequate acceptance criteria in the Standby Liquid Control System Preoperational Test. No enforce-ment sanctions will be considered for this deficiency because the licensee had not received Inspection Report No. 50-341/82-13 at the time of the inspection and has not had time to respond to the concern. This is considered an additional example of noncompliance.
h.
The procedure requires that, when testing the MSLIVs, a water head of > Pa be placed on the inboard valves when determining outboard valvc leakage. The inspector is concerned that water leaking into the test volume could mask the true leakage measured by the inflow gas test method. The licensee has agreed to revise the test to specify a water pressure of < Pa.
1.
The procedure does not contain steps to verify that test, vent, or drain connections will not contribute to the leakage for penetration flow paths.
J.
The procedure does not contain the test method to be used for testing the Traversing Incore Probe (TIP) system penetrations.
The licensee will include appropriate testing in lieu of the present "later" following resolution of testing methods with the NSSS vendor.
k.
The prccedure does not adequately address the quality of leakage testing mediums (air, nitrogen, and water).
1.
The procedure is currently being revised to use a gas blanketed water tank for water testing in lieu of the hydrostatic test pump currently required.
The procedure currently requires a minimum 15 minute post m.
pressurization stabilization period prior to recording leakage data.
It does not contain provisions for verifying the accuracy of measured leakage. The inspector is concerned that lack of temperature stabilization (especially as would be experienced if the test gas were colder than ambient temperatures for inflow testing) could reduce the indicated leak rate, therefore making the test nonconservative. The licensee will evaluate this concern.
_
-
..
-
- -
.
-
-
.
,
,
.
.
n.
The inspector determined that the testing commitments and techniques employed in Type C -testing of the' MSLIVs agrees with
.
the intent of the method approved for other licensed BWRs.
In.
reviewing 'the testing methods for these valves, however, the inspector noted that the design basis for.the allowable MSLIV leakage is to limit the site boundary dose following' automatic
isolation of the steam lines following a design basis fuel failure accident.~ -The test pressure applied in Type C testing
~
the valves.is based upon post LOCA' conditions. As a result, the valves are tested at 1/2 Pa, or approximately-25 psig (1/2 Pa is allowed in lieu of Pa because of the difficulty in testing at the_ normal Type C test pressure - Pa). During post fuel failure accident isolation conditions the valves must exhibit < 25 scfm leakage at >-1,100 psig (relief valve setpoint).
Prior to the. installation of MSLIV Leakage Control Systems-at BWRs, the MSLIV leakage limit was normally 11.5 scfm.
The inspector has two concerns of potential safety hazards:
(1) The effect of possibly greater MSLIV leakage rates when challenged at their design point-(> 1,100 psig) than that
"
experienced at the test point (< 25 psig); and, (2) The potential adverse results of overburdening the MSLIV Leakage Control System if concern (1) above results in a substantially greater leak rate than that measured'during Type C testing.
,
This is a generic concern, in that it will be reviewed for its applicability to Boiling Water-Reactors. The licensee is in compliance with. current regulatory requirements for the testing
,-
]
of MSLIVs.
!
. Items a. through n. will be tracked as Unresolved Item 341/82-16-01.
The licensee was advised by the inspector that continuation of final Type C testing of containment isolation valves prior to resolution of
>
applicable concerns identified in a. through n. above could invalidate the test results.
No additional items of noncompliance were identified.
5.
Containment Integrated Leak Rate Test (Type A Test)
The inspector noted that the licensee had committed to utilizing the test technique commonly referred to as the " Reference Vessel Method"
to accomplish the Type A test requirement of 10 CFR 50, Appendix J.
Following the docketing of the Fermi 2 FSAR, failures of this testing
<
method to produce acceptable test results at numerous facilities has
.
resulted in it be.'ng generally unacceptalbe to the NRC.
Interviews with licensee management and responsible testing personnel established
'
_
.
- -
-, -
..
. - -. --
.
.-.
"
o that the licensee is fully appraised of this concern, and that he has responded by changing his test program to use the " Absolute" test method. The licensee is also voluntarily conforming to newer industry standards for conduct of the Type A test.
The inspector is satisfied that the licensee is following a course of action which is conservative, and which demonstrates best engineering judgement. The licensee was asked to insure that adequate documentation of this test program change was documented the FSAR (0 pen Item 341/82-16-02).
6.
Control of Equipment The inspector conducted an inspection of the Reactor Core Isolation Cooling (RCIC) system to evaluate the effectiveness of jurisdictional and equipment status controls in use for equipment released for pre-operational testing. The results of the inspection, and resulting meetings with the licensee's management and testing personnel, resulted in several findings which summarize the current status of these controls.
a.
The licensee appears to have a documented record of each con-struction completion, nonconforming, damaged, and rework item for the RCIC system.
b.
The RCIC system is currently documented as having approximately 40% of the construction (CAIO) testing requirement completed.
However, the equipment itself is considered severely degraded, owing to the large number of items which are damaged, noncon-forming, or which otherwise require replacement, repair, or maintenance prior to being acceptable. _The test engineer is responsible for assuring that test requirements are repeated for items already tested which are subsequently damaged, degraded, or replaced. The RCIC test engineer had current records of status for each such item checked.
The licensee's QA implementing procedures contain requirements c.
which implement the requirements of 10 CFR 50, Appendix B for identification of nonconforming items. Nonconforming items in the RCIC system were not identified in accordance with these procedures. Upon further evaluation of the situation, it appears that the entire RCIC system is scheduled for refurbishment prior to a 100% construction and preoperational testing effort. This refurbishment effort is required to remedy expected degradation which occurred during extensive delays between equipment instal-lation and testing, and damage which apparently occurred as a result of poor housekeeping and construction practices during extended periods of time.
The inspector's concerns that (1) variances between regulatory and licensee procedural requirements and implemented controls (which appear to be forced by licensee efforts to rectify unacceptable conditions)
will result in inadequate identification and jurisdictional controls, and (2) that when the preoperational test program activity level peaks
'
,
to meet the scheduled June 1982 fuel load date (the potential exists for 50 or more tests proceeding simultaneously) the strain upon the existing system of controls may result in a breakdown of those controls.
These_ concerns were presented at the exit meeting, and in meetings with testing personnel, System Completion Organization Management, and Quality Assurance Manegement. The QA Management has committed to review, the inspector's concerns and existing controls and their implementation.
These matters will be resolved in the next preoperational test program inspection (Unresolved Item 341/82-16-03).
No items of noncompliance were identified.
7.
Housekeeping The inspector toured most areas within the reactor and auxiliary buildings to determine whether the poor housekeeping conditions noted during the previous inspection (Inspection Report No.-50-341/82-13) were being improved.
It was found that conditions were generally improved.
The inspector-did, however, note several conditions which are not considered acceptable:
a.
It was found that a log is maintained to control materials entering the reactor pressure vessel (RPV). The inspector toured the RPV and noted verious materials within it (including four large "C clamps," a stainless steel wire brush, and a magazine).
Inspection of the log entries failed to reveal a record of these items entering the RPV. Additionally, several items which appeared to be logged into the RPV did not appear to be present in it.
The guard controlling RPV access and maintaining the log was questioned, and he explained that he was not familiar with the proper procedure for implementing the log.
The inspector discussed this situation with licensee mcnagement.
It is agreed that the probability for degrading components impor-tant to safety is remote at this time because a 100% inspection of the RPV and internals is still possible at this stage of construc-tion. However, numerous vessel piping penetrations (including main steam and HPCI steam) were easily accessible because of installed temporary platforms, and were not covered. Since the vessel connected piping has already been cleaned and accepted, there are-no apparent controls to prevent the intrusion of tools or debris which could pose a safety concern (Unresolved Item 341/82 16-04).
The licensee expressed an aggressive posture to rapidly remedy this situation with the contractor responsibic for the RPV.
b.
General accumulations of construction debris and litter were largely reduced. Accumulations of bulk materials (threaded rod, steel shapes, etc.) were found tagged for removal from areas where they did not cppear to serve an intended purpose. The inspector noted that equipment protective covers were replaced in many areas where work was not actually in progress, however, two instances of
,
_
_
._-
_
~
a hinged covers on electrical junction boxes resting upon exposed permanent wiring were found.
Numerous components were found in areas where construction or main-tenance to safety related equipment was progressing which were not identified, and which were stored in environmental conditions which would not be acceptable for safety related components. A valve motor operator, gear train, stem, and disc which were apparently removed as a unit was found in the RCIC/ Core Spray Room with no identifying markings or tags, and standing in a shallow pool of water. The licensee later identified the assembly as non-safety related (room sump pump isolation valve).
The licensee is still in the process of responding to the housekeeping noncompliance resulting from the Construction Team Inspection (August 1982). The inspector informed licensee management of his continuing concern that poor housekeeping practices are contributing to degrada-tion of controls for component storage, segregation, protection, and environmental requirements.
The licensee was also appraised of the inspector's concern that poor houscaceping practices could result in (1) contamination of piping which has been cleaned and accepted for cicanliness, and (2) degra-dation of safety related equipment after preoperational testing and turnover to operations personnel.
The licensee appeared receptive to the inspector's concerns, and appears to be aggressively remedying the situation. No instances of final accepted equipment degradation have been noted to date.
However, only one system (TBCCW) has been accepted to date.
The inspector noted that the licensee is still in the process of responding to an item of noncompliance which was documented in the Construction Appraisal Team report, which was issued in August 1982.
No items of noncompliance were identified.
8.
Test Personnel Training The inspector selected a random sample of five test program personnel (including licensee, vendor, and contractor employees, and individuals certified at Levels I, II, and III). The qualification records for these individuals were examined to verify that the licensee's procedures and commitments for training and certification were being observed, and that the requirements of ANSI N45.2.6 were being met as a minimum.
It was found that, in all cases, technical experience and training requirements were met or exceeded, and that verification of physical requirements (such as vision acculty) were met.
Additionally, the method and documentation for scheduling recertification was found to be adequate. The inspector noted that changes in forms used to docu-ment certifications, and differences in documentation techniques for
-
.
,
employees of different organizations made historical files difficult to understand. The licensee has recently improved his certification documentation,-and it appears that the new forms and methods improve the quality of documentation. On this basis, further historical record changes are not considered necessary.
No items of noncompliance were identified.
9.
Remote Shutdown Procedures The inspector met with licensee representatives to evaluate planned actions in response to the commitment to develop procedures to safely shutdown the plant in the event that a fire disrupted power distribution system control functions at the control room and the remote shutdown panels (Re: NUREG-0798, "Enrico Fermi, Unit 2, Safety Evaluation Report, Supplement No. 2).
The licensee had begun efforts to develop the procedures. However, further clarification of the wording in NUREG-0798, Supplement No. 2 and the commitment documented in the licensee's letter of January 4, 1982 appears to be required before the acceptable scope of equipment to be addressed in the procedures is understood. The inspector will refer this matter to NRR for clarification (0 pen Item 341/82-16-07).
10.
Independent Inspection Effort The inspector toured numerous areas containing safety related equipment in the reactor and auxiliary buildings. Findings in regard to clean-liness and control of equipment are discussed earlier in this report.
Additionally, the status of installation and/or maintenance-repair activities was observed for the Recirculation Pump Motor-Generator
'
sets, cable pulling activities, Main Steam Line Isolation Valves, Control Rod Drive Hydraulic System Piping, and field rework of the RPV moisture separator assembly hold-down mechanisms. Conditions were found to be satisfactory except for concerns noted earlier. A spot check of procedures, adherence to procedures, and QC activities was made for the moisture separator work. The procedure was found adequate for the work being accomplished, and was being observed.
The assigned QC inspector was interviewed, and found to understand the quality requirements of the work and actively verifying quality as work progressed.
The inspector observed evidence of previous water flooding in the RCIC-Core Spray Pump Room (water marking and damage to tags and porous materials). A later discussion with the cognizant test engineer and management verified that a malfunction of the room's sump pumps resulted in water flooding. The licensee performed insulation resistance checks for electrical cables which were wetted, and the cables are acceptable.
The licensee did not, however, perform an inspection of the internals of instruments which may have been adversely affected. He has now committed to do so (0 pen Item 341/82-16-06).
-
-
.
.,
,
11.
Unresolved items-
' Unresolved items are matters about which more information is required
-
in order to ascertain whether they are acceptable items, items of non-compliance, or' deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 4, 6 and 7.
12.
Exit Meeting The inspector met with licensee representatives identified in Para-graph 1.
The licensee acknowledged the inspection findings. The licensee responded to the matter of RPV cleanliness and material control by committing to take immediate and comprehensive corrective action. Licensee QA and Systen Completion Organization' management requested a post-exit meeting conference to discuss the inspector's concerns in regard to material and component jurisdictional and status controls (such as tagging) and housekeeping (especially in regard to protecting equipment from being degraded during the time between preoperational test acceptance and fuel load). All parties felt that the concerns were understood and needed to be addressed at the end of the meeting. The licensee suggested that a followup meeting be scheduled for the next inspectf., at which time he will present his assessment of programmatic controls and plans for improvement to the.
program (if warranted). The inspector concurred in this course of action (0 pen Item 341/82-16-05).
!
.
-
.
.
.
-
.