IR 05000341/1983004
| ML20023C401 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/27/1983 |
| From: | Reimann F, Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20023C387 | List: |
| References | |
| 50-341-83-04, 50-341-83-4, NUDOCS 8305170304 | |
| Download: ML20023C401 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION Report No. 50-341/83-04(DE)
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 2 Site, Monroe, MI Inspection Co uct February 14 through March 17, 1983
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Approved By:
L. A. Rey s, Chief WIIt Programs Section Date Inspection Summary Inspection on February 14 through March 17, 1983 (Report No. 50-341/83-04(DE))
Areas Inspected: Routine, unannouned inspection by regional inspector for followup on licensee actions in regard to inspector identified concerns in the area of containment local leak rate testing, review and witnessing of other preoperationi tests and assessment of general plant conditions.
The inspection required 114 inspector-hours, including 35 inspector-hours during offshifts.
Results: Of the three areas inspected:
(1) no items of noncompliance were noted in one' area, c'ontainment leak rcte testing; (2) three items of noncom-
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pliance vere noted in regard to Diesel Generator Preoperational testing (Paragraph 3.d), and (3) two items of noncompliance were noted in regard to general plant conditions (Paragraphs 3.b and 4.a).
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r 8305170304 830427 DR ADOCK 05000341 PDR
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DETAILS 1.
Persons Contacted
- W.
Holland, Vice President
- F. Agosti, Manager Startup R. Lemberger, STE-NSSS
- G. Trahey, Project Quality Assurance
- T. Nicholson, Startup Engineer
- T. Mintun, Startup Director
- J.
Icard, Startup Assurance Engineer
- P. Acharya, System Completion Organization
- J. Ford, Lead System Test Engineer, B0P
- A. D. Peluso, Lead System Test Engineer, Control Center
- F. Kohn, Lead System Test Engineer, Electrical
- M. A. Michalek, System Completion Organization
- G. F. Ramsey, Maintenance
- D. H. Elliott, Maintenance
- F. Dunn, SSTE, I&C
- E.
H. Newton, QA Supervisor
- E. D. Griffing, Superintendent, Nuclear Production
- C B. Collings, Administration Engineering, Startup J. W. McCready, System Test Engineer B. Delaney, Shif t Supervisor M. Batch, DECO Engineering
- Identified those present at one or more of the exit meetings conducted on March 14, and March 16, 1983.
The inspector interviewed members of the licensee's startup, instru-mentation and controls, operation, maintenance, and system completion staffs in addition to those identified above.
2.
Licensee Action on Previously Identified Items (OPEN) Unresolved Item (341/82-16-01(DE)): Licensee is reviewing new local leak rate test procedures. The inspector confirmed that no final acceptance local leak rate testing is being conducted.
(OPEN) Unresolved Item (341/82-16-03(DE)): Licensee procedure revisions are not complete as of this inspection. Paragraph 3.b below contains a noncompliance in regard to this item.
(OPEN) Open Item (341/83-01-03(DE)): Samples sent offsite for analysis have not been completed as yet.
3.
Preoperational Testing Activities a.
HPCI and RCIC Refurbishment: The inspector interviewed cognizent startup personnel and toured the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) pump rooms. The
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planned refurbishment of the two system's turbines, pumps, and major valving had been completed.
It was determined that the licensee is re-evaluating the validity of all construction testing that had been completed on these systems prior to the start of refurbishment, and that most, and possibly all, of that testing will be repeated for added assurance that refurbishment activities did not alter the post-test equipment condition.
No items of noncompliance or deviations were identified.
b.
HPCI and RCIC DC Power Cables: The licensee presented updated information to the inspector in regard to the adequacy of imple-mented provisions for identification and segregation of
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nonconforming cables, which required replacement or modification to remedy a deficiency in a report filed pursuant to 10 CFR 50.55(e).
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The new information concluded that unique identification numbers
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were not assigned to all of the replacement cables. The noncon-forming cables had not been physically identified as required by Paragraph 2.5.9 of the QA Manual, nor were actions taken to segregate cables which had been partially or fully removed from their respective conduits from cables which were acceptable. The above condition of failure to identify and segregate nonconforming
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cables had been in existance since prior to November 1982.
This condition appears to be in noncompliance with 10 CFR 50, Appendix B, Criterion XV, and Paragraph 2.5.9 of the licensee's QA Manual (341/83-04-01).
c.
HPCI Turbine Alignment: The startup test engineer responsible for construction and preoperational testing of the High Pressure Coolant Injection System (HPCI) informed the inspector of mechanical alignment problems being experienced with the HPCI
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Turbine / Pump unit.
As a result of discussions with the responsible
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startup test engineer, and a review of documentation in his posses-i sion, the inspector finds that; (1) actions to analyze and remedy the problem are timely and appropriate, (2) the licensee's
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engineering organization and equipment vendor representatives are being effectively utilized in analyzing and correcting the problems, and (3) documentation of the problem and corrective actions is appropriate. The inspector raised a concern that, following corrective actions to allow cold alignment of the turbine / pump
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unit, differential thermal expansion of the unit's rotating j
components and connected piping could result in misalignments which j
could degrade the HPCI system. The licensee's staff is in agreement
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with the concern, and has committed to include appropriate pro-cedural requirements in post fuel load hot testing procedures to verify that the corrective actions for cold alignment difficulties i
will not be negated by hot operations.
(0 pen Item 341/83-04-02)
No additional items of noncompliance or deviations were identified.
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d.
Emergency Diesel Generator (EDG) Preoperational Testing: The inspector reviewed portions of Preoperational Test Procedure PRET.R3000.001 " Emergency Diesel Generator System", reviewed pro-cedure results accumulated to date, toured the areas containing system equipment, interviewed cognizant management and support personnel, reviewed maintenance evolutions on EDG 11, and witnessed tests in progress on EDG 11.
(1) The EDG 11 subsystem was toured by the inspector on March 1, 1983. General cleaniiness and equipment condition was observed to be good. The licensee had just declared the progressing sequence of 23 reliability start tests on EDG 11 a failure as a result of a decreasing trend in fuel oil pressure on each successive run, which eventually would have resulted in an automatic engine trip on low fuel oil pressure. The malfune-tion was diagnosed as a leaking relief valve on the discharge piping of the positive displacement fuel oil pump. At the time of the inspector's tour the leaking relief valve had been removed for repair. The inspector noted that the piping routed to and from the removed valve had been left open (i.e., not covered or capped to prevent the entry of foreign material).
This practice is contrary to good practice. The licensee took prompt action to cover the open pipe ends.
The inspector also noted that six I&C leads routed to a junction box mounted on the generator had been de-terminated for the purpose of taking local readings using temporary test equipment. The leads were not tagged in accordance with the temporary modification procedure. The inspector reviewed the master copy of the procedure with the test technician on shift.
No record of the temporary modification in regard to controls for lifting and verification of proper re-termination cf the leads was found.
Instructions as to which leads specifically should be used for the aquisition of items of test data were also lacking.
It was verified that the shift supervisor on shift had no record in the Active Temporary Modification File of the lifted leads, as required by his interpretation of site procedures for controlling jumpers and lifted leads during preoperational testing.
During subsequent meetings with licensee management personnel it was determined that Procedure 4.7.2.01, which controls temporary modifications of this type, was not properly followed.
It was further determined that the procedures allows for two alternate, yet different methods for controlling temporary modifications.
Both procedural options were alternatly in use to control other temporary modifications currently in progress on EDG ll, and in other portions of the plant equipment.
One of the two options (use of a yellow caution tag in lieu of a orange and white temporary modification tag) bypassed the central control function of the shift supervisor's Active Temporary Modification File.
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The failure to adequately control the temporary modifica-tion in the test procedure, the failure to properly control and tag the lifted leads, and the existance of two differing systems for the logging and control of the same type of temporary modifications are considered to be in noncompliance with 10 CFR 50, Appendix B, Criterion V and licensee committ-ments to implement 10 CFR 50, Appendix B, (as described in the Notice of Violation accompanying this report) (341/83-04-03).
(2) On March 2, 1983, the inspector witnessed EDG 11 reliability start testing conducted in accordance with PRET R3000.001.
Prior to commencing the actual start tests, the inspector interviewed cognizant personnel and observed evolutions to prepare EDG 11 for operation, including the repair of the leaking fuel oil relief valve described in (1) above. The relief valve had been replaced with a new valve identified as
" identical" to the one which had been leaking. Two successive bench tests were conducted to verify that the lift and rescat pressures of the new valve were such that the vendor technical manual recommended fuel supply pressure limits would not be exceeded.
The inspector witnessed five successive attempts to manually start and synchronize EDG 11.
The first four attempts failed, the fifth attempt was successful. Of the four failures, all were diagnosed as being caused by circumstances which, if correct, would have represented design and equipment inadequacies in the EDG and support system. The failures were not thoroughly investigated or documented as required by the test procedure and test program management procedures. A more detailed analysis performed at the request of the NRC inspector identified the four failures as resulting from failure to perform mechanical prerequisite lineups as required by the pro-cedure, improper fuel oil pressure resulting from differencies between the original and replacement relief (or pressure regulating) valves, and failure to use operating procedures (as required by the test procedure) for operating the EDG. This appears to be in noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion XI which requires that testing be performed in accordance with written test procedures (341/83-04-07).
Following corrective actions to the deficiencies described above the inspector witnessed the first two tests in the restarted sequence of 23 start reliability tests.
EDG 11 was observed to perform well, and procedures were adhered to.
The inspector met with the involved individuals and licensee management immediately. The details of the above finding were discussed, including inspector concerns that three vertical levels of test program management and one QC inspector had also witnessed the above described sequence of events, and
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none of these individuals diagnosed or initiated corrective actions for the deficiencies observed. Upper licensee manage-
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ment concurred in the inspector's concern that the sequence of events observed would not result in adequate demonstration of the adequacy of the EDG's.
Immediate corrective action steps initiated by licensee management include (1) an immediate evaluation and analysis of the circumstances surrounding the four start failures, as required by licensee procedures and regulations, (2) the assignment of an impartial licensee staff member to perform interviews and evaluations of the personnel and management interactions which resulted in the observed breakdown in test program conduct (action began within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the inspector's concerns being surfaced), and (3) test results were stricken from the count of 23 successful con-secutive starts required to demonstrate reliability of EDG 11.
The breakdown of test program controls described above is in noncompliance with 10 CFR 50, Appendix B, Criterion XI.
(341/83-04-04 ).
The inspector will followup on the results of the management study of the circumstances causing this noncompliance, and resulting corrective actions (0 pen Item 341/83-04-05). The licensee's vice president for operations issued a memorandum immediately to all cognizent staff members which mandates adherence to test program controls.
l (3) A management meeting was held on March 14, 1983 between licensee corporate and site management and NRC resident inspector, the Regional Test Program Section Chief, and the inspector. The significance of the findings was discussed, and licensee management restated their committment to assure that procedural requirements are observed in all phases of the testing program, e.
Containment Leak Rate Testing: The inspector interviewed several individuals involved in local leak rate testing and determined that
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approval of the procedure revision required prior to restart of testing is scheduled for one to two weeks in the future.
It was
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confirmed that no preoperational testing was in progress pending completion of the revision and approval of the test procedure.
(Work in this area has been stopped as documented in Inspection
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Report No. 50-341/83-01),
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The inspector provided to the licensee, at his request, a copy of known corrections to industry standards which affect Type A
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Integrated Containment Leak Rate Testing.
The inspector also provided to the licensee guidance in regard to the NRC position on acceptable documentation of justifications for local leak rate testing of containment isolation valves in the reverse direction (i.e., the direction of flow which is opposite
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I of the direction in which the valve must prevent flow during post-accident conditions). On March 15, 1983 the inspector met with individuals responsible for local leak rate ttsting and a repre-sentative of the licensee's engineering staff.
It was agreed that the licensee would review the configuration of containment piping penetrations and verify that the requirements of 10 CFR 50, Appendix J are adequately complied with, including reviews of valve designs to verify that reverse testing decisions are justifiable.
A final review of the acceptability of cases where the licensee proposes to reverse test valves will be tracked concurrent with existing open item number 341/82-16-01 (which addresses a complete review of the upcomming revision to the local leak rate testing procedure).
f.
Control Rod Drive System Testing: The inspector witnessed activi-ties related to testing of the Control Rod Drive System Hydraulic Control Units (CRDH-HCU's). At the close of the inspection actual preoperational testing activities were proceeding at a slow pace as a result of the need to resolve a number of minor deficiencies and malfunctions affecting the test.
Specifically, difficulties were being encountered with loose limit switch actuating devices, minor water and nitrogen leaks in accumulator tanks and interconnecting piping, leaking packing glands on scram inlet and outlet valves, and other similar problems. The testing in progress consisted of initial oressurization, final flushing, flow rate adjustment, and
" accumulator trobule" level and pressure logic verification. The inspector verified that actual testing, as well as repairs and adjustments, were accomplished in accordance with appropriate approved procedures; that adequate surveillance was being accomplished by the QC and QA organizations by individuals who were familiar with procedural requirements; and that adequate controls existed for procedure and drawing changes. No adverse findings were identified. The inspector noted the positive effects upon l
cleanliness and equipment controls resulting from the licensee's
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having built " clean rooms" around the CRDH-HCU's, the use of security guards to control access into the clean rooms, and con-tinuous implementation of the so-called "two man rule" which requires that all access by individuals into the clean rooms be accomplished by two or more individuals, normally one of whom is a cognizent testing individual or a representative of QA.
A type of oil (possibly caster oil) was observed to be leaking from the mechanical joint formed by the cylindrical section and bottom head of two of the CRDH-HCU water / nitrogen accumulators.
It is
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presumed that an unknown quantity of the oil is present either
between the cylinder to bottom head mechanical closure or inside of the accumulator itself (in the lower-nitrogen side), and that the nitrogen precharge pressure in the accumulator is forcing the oil
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through leaks. Two concerns result from this observation, (1) the effect that the oil may have on CRDH-HCU performance (or the NSSS if it migrates beyond the CRDH-HCU's), and (2) the effect of the leaks on the ability of the two accumulators (or others) to perform
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their intended function. The concerns will be tracked as open
items (341/83-04-06).
No other items of noncompliance or deviations were identified,
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t 4.
Independent Inspection Effort - General Plant Conditions The inspector toured numerous portions of the plant containing equipment
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which is important to safety, including ECCS pump rooms, emergency bat-teries, main steam tunnel, reactor water cleanup system, main control
room, remote shutdown panels, assorted cable rooms and cable pull areas,
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auxiliary electric room (relay room), Division I and II electrical
switchgear rooms, RHR complex, portions of the radwaste system, and the primary containment. Particular attention was given to the control of equipment status tags, seggregation and storage of safety related equipment and materials, housekeeping practices as they relate to the environmental requirements of safety related components, and general j
equipment condition.
Continuing improvement from unacceptable conditions existing in mid
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1982 was noted in most areas. The inspector noted the increasing use
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of security personnel to control acess to areas containing equipment
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which is essentially completed, locked doors and barriers to control
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unauthorized access to vital equipment areas, and the beneficial effects of the licensee's program to clean up and paint many reactor building spaces on an " area by area" basis.
The inspector noted unacceptable housekeeping practices in a cable tray
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room adjacent to the Auxiliary Electric Room (Relay Room). Several cable
trays containing safety related cables were observed to contain rags, ropes, an electric fan, concrete expansion anchors, food waste, various lengths of conduit and small bore pipe, tools, wood debris, and assorted construction debris. These unacceptable items apparently accumulated in the cable trays as a result of poor construction housekeeping practices associated with on-going rework of cable tray supports in the cable tray room.
Similar conditions resulted in a noncompliance reported in Inspection Report No. 50-341/82-10. The inspector notes that general cable tray cleanliness has improved since mid-1982, and that the unacceptable l
conditions cited above appear to be isolated to the cable tray room described.
I The housekeeping conditions in the cable tray room appear to be in
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noncompliance with 10 CFR 50, Appendix B, Criterion II as described
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in the enclosed Notice of Violation.
No other items of noncompliance or deviations were noted.
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5.
Unresolved items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of
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noncompliance, or deviations. An unresolved item disclosed during the inspeciton is discussed in Paragraph 2.
6.
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 both. Open items disclosed during the inspection are discussed in Paragraphs 2 and 3.
7.
Exit Meeting A preliminary exit meeting was held on March 14, 1983 at which time the Regional Test Program Section Chief, the resident inspector, and the in-spector discussed concerns regarding the observered deficiencies in the testing of Emergency Diesel Generator 11 with licensee management.
Licensee management acknowledged the NRC concerns, and assigned action items to site management to provide for prompt corrective actions. The detailed concerns are discussed in Paragraph 3.d of this report.
The inspector met with the licensee representatives identified in Paragraph 1 of this report on March 16, 1983 and present the findings described in this report. The licensee acknowledged the findings.
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