IR 05000341/1987009

Insp Rept 50-341/87-09 on 870202-0303.Violations Noted: Failure to Follow Procedures in Identifying out-of-spec Condition & Failure to Define Responsible Organizations for Notification That Instrumentation Not Calibr

ML20204J573
Person / Time
Site:	Fermi
Issue date:	03/12/1987
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204J515	List: IR 05000341/1987009 ML20204J511 ML20204J547
References
50-341-87-09, 50-341-87-9, NUDOCS 8703270266
Download: ML20204J573 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION III

Report No. 50-341/87009(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: Fenni Site, Newport, MI e 'b Inspection Conducted: February 7 thru March 7,1987 Inspectors: W. G. Rogers M. E. Parker fcL Y k- /

Approved By: E. G. Greenman, Deputy Director /2/d7 Division of Reactor Projects Date'

Inspection Summary Inspection on February 2 thru March 3, 1987 (Report No. 50-341/87009(DRP))

Areas Inspected: Rou';ine, unannounced inspection by resident inspectors of previously identified violations, inspector identified items, operational safety, maintenance, surveillance Licensee Event Reports, report review, plant trips, events, and management meeting Results: Two violations were identified (paragraphs 5 and 6, failure to follow procedures in identifying out-of-specification condition and paragraph 6, failure to clearly define the responsible organizations for notification that instrumentation was out of calibration). One unresolved item was identified (paragraph 6). No deviations or open items were identified, pg Eg g 0500034 g7o33, o

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DETAILS Persons Contacted Detroit Edison Company

• F. Agosti, Vice President, Nuclear Operations L. Bregni, Compliance Engineer

• S. Catola, Chairman, NSRG

• 0. Earle, Technical Engineer, Nuclear Production

+ J. Flynn, Corporate Attorney

+*S. Frost, Licensing Engineer, Licensing

• J. Green, Systems Engineering Supervisor, Nuclear Engineering J. Leman, Superintendent, Maintenance and Modification

+*R. Lenart, Plant Manager, Nuclear Production L. Lessor, Consultant to the Plant Manager, Nuclear Production

+*R. May, Maintenance and Modifications Superintendent G. Ohlemacher, Assistant Maintenance Engineer

++ Orser, Vice President, Nuclear Engineering

+ J. Plona, Assistant Operations Engineer E. Preston, Operations Engineer

+*T. Randazo, Director, Regulatory Affairs W. Ripley, Startup Director S. Sharma, Systems Engineering

• L. Schuerman, General Supervisor, Nuclear Engineering

• B. Sheffel, ISI/ PEP Supervisor, Nuclear Production

• F. Sondgeroth, Licensing Engineer, Licensing

• H. Stockman, IST Engineer, Nuclear Production

• F. Svetkovich, Technical Group, Nuclear Production

+*B. R. Sylvia, Group Vice President, Nuclear Operations

• J. Tibia, Systems Engineer, Nuclear Engineering

+*G. Trahey, Director, Quality Assurance

• W. Tucker, Acting Superintendent, Operations U.S. Nuclear Regulatory Conmission:

+ M. Farber, Region III

+ E. Greenman, Region III

+ J. Grobe, Region III

+* Parker, Resident Inspector

+ P. Pelke, Region III

+* Rogers, Senior Resident Inspector

• Denotes those who attended the exit meeting on March 5, 1987.

+ Denotes those who attended the Enforcement Conference on February 23, 1987, at Region II The inspectors also interviewed others of the licensee's staff during this inspectio o

. . Followup on Violations (92702)

(Closed) Violation (341/86026-03(DRP)): Failure to post firewatc This violation concerned the failure of the licensee to post a one-hour firewatch upon discovery of the inoperable diesel fire pump room wet pipe sprinkler system on September 8,198 As described in the licensee's letter VP-86-0173 dated December 3, 1986, the Nuclear Assistant Shift Supervisor (NASS) involved with the

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surveillance review was counseled concerning the importance of adequately identifying Technical Specification Limiting Conditions for Operation and taking appropriate steps to prevent such violations. A description of the event was placed in the Night Order Log for control room shift j management to reinforce the need to thoroughly review documentation to ensure Technical Specification compliance. ReviewofPN-El(WorkOrder)

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i 654683 and 800641 identified that the flow switch was defective and that no replacements were in stock. The licensee continued to maintain the l hourly fire watch patrol until receipt, installation, and testing of the l new flow switch on October 11, 198 I Inspection Report 50-341/86026 identified that the Nuclear Shift

, Supervisor (NSS) on a subsequent shift realized the Technical I

Specifications had not been met and took immediate action to establish an hourly fire watch.

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This violation is considered closed.

l 3. Followup on Inspector Identified Items (92701)

l (0 pen)OpenItem(341/84020-05(DRP)): Labeling of control room meters / displays. The inspector met with the cognizant individual The individuals stated that a schedule for completion of the labeling program will be docketed to the NRC in June of 198 Followup on these items will be based upon that schedul (0 pen)OpenItem(341/84020-07(DRP)): Labeling of alarm points on control room recorders. Followup same as paragraph a. above.

l (0 pen)OpenItem(341/84020-08(DRP)): Labeling of range markings l on control room recorders. Followup same as for item a. above.

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l (Closed)UnresolvedItem(341/86022-01(DRS)): Inadequate review l of Nuclear Operations Procedures (N0P). All NOPs were reviewed I with no substantive changes improperly reviewed. This matter is considered close (0 pen)OpenItem(341/86026-02(DRP)): Fuse Specification EJ Corrective Actions. The licensee has completed the walkdown of all electrical panels that did not require de-energization. DER 87-029 was written documenting all discrepancies. To date, no system has been rendered inoperable due to the discrepancies. The additional

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locations requiring inspection at a maintenance outage have been identified and work requests assigned to do the inspections. When these work requests are performed and all discrepancies resolved, this item will be considered close . Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period from February 3 thru March 2, 1987. 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 Emergency Equipment Service Water system to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could degrade perfomance; and verified that instrumentation was properly valved, functioning, and calibrate 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 S. MonthlyMaintenanceObservation(62703)

Station maintenance activities on safety-related systems and components listed below were observed to ascertain that they were conducted in a:cordance 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 the status of cutstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed:

High Pressure Coolant Injection Turbine Thrust Bearing Inspectio High Pressure Coolant Injection Turbine Rotor Replacemen On February 17, 1987, a masonry wall between the turbine building and the auxiliary building was removed in order to make access for the High Pressure Coolant Injection turbine rotor. This wall is a flood protection wall and a Technical Specification fire wall. The necessary 10 CFR 50.59 evaluation was prepared to address the degradation of the flood boundary and a continuously posted fire watch was implemented to satisfy Technical Specification fire protection requirements. During a followup review on Februar 18, 1987, the inspector questioned the NuclearShiftSupervisor(yNSS) and Nuclear Assistant Shift Supervisor (NASS) as to the reason that the Out-of-Service Log (OSL) had not been updated to reflect the degradation of the masonry wall. The inspector was informed that the OSL would be updated to reflect the degraded masonry fire wal On February 19, 1987, the inspector reviewed the OSL and it still had not been modified to reflect the masonry wall. The NASS informed the inspector that he reviewed the safety evaluation and determined that the masonry wall was not a Technical Specification fire wall and, therefore, did not need to be reflected in the OSL. The inspector informed the NASS that this is a Technical Specification fire wall and provided him the applicable sections of the FSAR. The NASS subsequently contacted the fire arotection specialist and concluded that the masonry was was in fact a Tccinical Specification fire wal P0H procedure 21.000.18, "Out-of-Specifications Log," Revision 7 dated February 17, 1987, states in paragraph 5.1.1 that; "When a system, subsystem, train, component, or device which is safety related or is otherwise required to be operable to satisfy Technical Specifications or IST is determined to be out of specifications, the NSS/NASS shall initiate Attachment 1, Out-of-Specifications Log Sheet following the sample in Enclosure 1."

This is a violation (341/87009-01(DRP)) of Technical Specifications 6.8.1.a in that the licensee failed to follow established procedures in identifying the out-of-specification conditio Following ccmpletion of maintenance on the High Pressure Coolant Injection System, the inspectors verified that these systems had been returned to service properl . .

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. MonthlySurveillanceObservation(61726)

The inspectors observed surveillance testing required by Technical Specifications and verified that: testing was performed in acenrdar.ce with adequate procedures, test instrumentation was calibrated, ifmiting 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, ano 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:

24.208.03 Division II EESW Pump and Valve Operability Tes *

24.404.03 Standby Gas Treatment System Valve Operability Tes .609 Rod Sequence Control System Functional Test (Group Notch

Control Checks).

44.020.27 Main Steam Line Pressure, Division I, Channel A Calibratio The inspectors performed a record review of completed surveillance test The review was to determine that the test was accomplished within the required Technical Specification time interval, procedural steps were properly initiated, the procedure acceptance criteria were met, independent verifications were accomplished by people other than those performing the test, and the tests were signed in and out of the control room surveillance log book. The surveillance tests reviewed were:

24.40S.03 Secondary Containment Integrity Tes .010.25 Main Steam Line Radiation, Division I, Channel A1/A,

Functional Tes .010.27 Main Steam Line Radiation, Division I, Channel A2/C,

Functional Tes .020.35 Main Steam Line Flow, Division I, Channel A Functional

Tes .020.37 Main Steam Line Flow, Division I, Channel C functional

Tes .020.47 Main Steam Line Tunnel Temperature, Division I, Channel A

Functional Tes .020.49 Main Steam Line Tunnel Temperature, Division 1, Channel C

Functional Tes *

44.030.205 Core Spray Pump C Discharge Pressure functional Test.

i 44.030.207 Core Spray Pump A Discharge Pressure Functional Tes *

44.030.214 RHR Pump B Discharge Pressure Functional Tes *

44.030.216 ECCS-RHR Pump D Discharge Pressur *

44.070.001 Control Rod Withdrawal Block-Scram Discharge Volume

Functional Tes .070.003 Control Rod Withdrawal Block-Scram Discharge Volume

function Test / Calibratio .210.001 Drywell Surp Level and Flow Functional Test.

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44.220.416 MSIV Leakage Control. Division II Reactor Vessel

Pressure Channel Functional Tes .080.01 Chemistry Surveillances (Attachments 21 and 24).

The inspector reviewed the manner in which the licensee complies with Technical Specification surveillance requirement 4.6.1.4.c. This surveillance requirement is associated with the Main Steam Isolation Valve Leakage Control System (MSIVLCS). The MSIVLCS function is to pressurize the main steam piping above reactor pressure to provide an additional barrier to prevent radioactivity leakage into the environment through the main steam lines in the event of a loss of coolant acciden The MSIVLCS consists of two subsystems. The division 1 subsystem injects air into the piping between the inboard and outboard MSIVs and maintains a pressure of 2 to 6 pounds above reactor pressure. The division 2 subsystem accomplishes the same task between the outboard MSIVs and the third MSIVs/ condenser drain valve. Surveillance requirement 4.6.1. is an 18-month test of each subsystem throughout its operating sequence verifying each interlock operates as designed and each automatic valve goes to its correct position. The licensee implements this requirement through performance of procedure 24.137.15. "MSIV Leakage Control System Functional Test." The inspector noted in the review that this procedure did not test the interlocks associated with the the " deactivate" mode of the system. The " deactivate" mode automatically secures the air supply for pressurizing the steam line piping when a predetermined time has expired and the piping is less than 2 pounds above reactor pressure. The design philosophy was that if the piping had not pressurized within the predetermined time frame, air may be injected into the containmen Also, steps 3.6 and 4.8 which check the system's ability to maintain the 2 to 6 pound differential should clearly state that the interlocks associated with the pressure control circuitry are all exercised. The inspector identified the testing deficiency to the licensee. At the exit meeting on March 5,1987, the licensce indicaged that the engineering analysis for continued air injection into a N inerted containment had not been performed. The licensee connitted to provide analysis results prior to inerting the containment. Failure to test the deactivate mode is considered an unresolved item (341/87009-02(DRP)) pending further analysi On February 9, 1987, the inspector reviewed surveillance test 24.208.03,

" Division II EESW Pump and Valve Operability Test," which was performed on February 2, 1987. During the review the inspector noted that the pump had been run twice without meeting the acceptance criteria in that the differential pressure parameter was in the unacceptable high range but, the Surveillance Performance Form cover sheet had been annotated as acceptable by the shift manager based on a telephone conversation with the Inservice Test En The inspector discussed the situation withInserviceTest(gineer(ITE).IST) personnel. The personnel indicated EESW division !! went into the alert range in January and this pump run confirmed that the reference curve for the pump was not correct. The IST personnel provided the inspector with a written evaluation Log No.87-031 stating the most probable cause for the incorrect reference curve was a change in the flow orifice calibration after the generation of the

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reference curve and the curve was not modified to compensate for the change. .The licensee established a new reference curve for both

. divisions of EESW on February 9, 1987. Following additional review by the licensee and the inspector, the licensee concluded that the real reason for the incorrect reference curve was the instrumentation used to establish the curve was not in calibration on the date of that pump run. All 33 ASME Section XI pump calibration records were reviewed to ,

determine if their reference curves were generated with instrumentation j which was subsequently determined to be out of calibration. ho other reference curves were found invali The inspector discussed the actions taken by shift supervisor when the  !

two pump runs were unacceptable, discussed the content of the shift manager /ITE telephone conversation. performed a historical review of i EESW pump division 2 performance, reviewed the administrative controls 90verning the ASME Section XI pump testing, reviewed the administrative (

controls established for evaluating inservice testing process  ;

instrumentation found out of calibratice., ar.d determired the training -

provided licensed operators /I&C foreman on Section XI administrative i requirement !

The results of these reviews and conversations were: ,

, Following the first pump run cos.pleted at 1500 on February 7,1987, the shift supervisor did not make an out of service log entry identifying EESW pump division II inoperable and the action statement for an inoperable EESW train applicable. However, the shift supervisor did consider the pump out of service under the Technical Specification The licensee did not exceed or violate the action statement for i'

an inoperable EESW trai Administrative procedures 21.00018. "Out of Specification Log",

step 5.1.1, and 12.000,61, " Inservice Testing Program for Pumps and Valves ", step 6.2.6.2, are adequate and clear in instructing the shift supervisor to declare the pump inoperable when the pump  ;

acceptance criteria are not met and enter it into the '

Out-of-Specification Lo j The senior licensed operators were provided Section XI training in f the initial licensing class but not in requalification trainin The licensee has issued a Training Request Form to include the Section XI requirements in requalification training, The administrative requirement in procedure 41.000.11. " Calibration of Process Instrumentation", step 4.1.2.2 requires out-of-calibra-tion IST instrumentation be identified to IST for their evaluatio However, the procedure does not specify who is responsible to accomplish this task. Informally, the I&C staff was sporadically accomplishing the notification. However, in some instances out-of-calibration instrumentation was not identified to the IST personne _ _ _ _ _ _ - _ _ _ _ _ _ - - _ _ _ _ _ _ - - _ _ _ _ _ _ - _ _

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Therefore, no evaluation was performed as to the validity of the last pump run. Instrumentation was out of calibration and IST not notified on EESW pump division 11 three times (April 16, 1984, August 26, 1984, and November 10,1984) and on EESW pump division I five times (April 14, 1984, August 26, 1984 November 9, 1984, January 22, 1985, and May 6, 1986). Recommend the licensee provide clearer administrative guidance as to how the shift supervisor accepts the ISE determination that an ASME Section XI pump is operable when it does not meet the acceptance criteria of the surveillance procedure, Recommend the pump performance curves be expanded to better facilitate data takin Recommend ISE evaluations be in writing prior to declaring equipment operabl The inspector considers the failure to make the Out-of-Specification Log entry at 1500 on February 7,1987, an example of a violation (341/87009-01(DRP)) of Technical Specification 6.8.1.a. in that the licensee did not implement established procedures governed by Regulatory Guide 1.33, Revision 2, February 1978, concerning equipment contro The inspector considers the failure to clearly define the responsible organizational unit for informing the IST personnel of IST instrumenta-tion that was out of calibration to be a violation (341/87009-03(DRP))

of 10 CFR 50 Appendix B Criterion V, Instructions, Procedures, and Drawing The licensee acknowledged the inspector's recommendations and stated that they would be considered. In some cases the licensee has already acted upon the . Licensee Event Reports Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 85003, IRM Scram While Restoring Division II 24 VDC Battery Charger B- (Closed)LER85012,ReactorScramsDuringRPSShortingLinkInstallatio (Closed) LER 85013, Secondary Containment Not Established Prior to Starting Core Alteration (Closed)LER85032,ReactorWaterCleanupContainmentIsolationValves De-energized in the Open Positio (Closed) LER 85035, Reactor Water level 3 Scram, Resulting from a Slow Water Level Decrease While Manually increasing Reactor Pressur . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _

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(Closed)LER85036,ReactorWaterCleanupContainmentIsolationValves De-energized in the Open Positio (Closed) LER 85037, Missed Surveillance Channel Check for Four Isolation Actuatior Instrument (Closed) LER 85038, Missed Reactor Core Isolation Cooling System Surveillanc (Closed) LER 85039, HPCI Stop Valve Oil Lea In addition to the review criteria stated above, the LERs were reviewed for potential violations of regulatory requirements. The results of that review identified violations of Limiting Conditions for Operation were associated with LERs 85013, 85032, 85036, 85037, and 85038. These violations occurred during the same time frame and were of the same type as the violations identified in Inspection Report No. 50-341/85040. As indicated in paragraph 9.d. of Inspection Report No. 50-341/86019, the escalated enforcement actions of Inspection Report No. 50-341/85040 adequately address these violations and no citations will be give No other 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 January 1987. The inspector confirmed that the information provided met the requirements of Technical Specification 6.6.A.3 and Regulatory Guide 1.16.

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No violations or deviations were identified in this are . FollowupofEvents(93702)

During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the events onsite with licensee and/or other NRC officials. In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the licensee was taking prompt and appropriate actions, that activities were conducted within regulatory requirements and that corrective actions would prevent future recurrence. The specific events are as follows:

February 5, 1987 - Control center HVAC trip to recirculation mod February 12, 1987 - Manual isolation of reactor water cleanup system due to high differential flo ;

February 22, 1987 - Initiation of a shut down due to HPCI

inoperabilit February 25, 1987 - Both divisions of low pressure coolant injection ,

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February 26, 1987 - Reactor scram due to turbine generator tri March 1,1987 - High pressure reactor scra No violations or deviations were identified in this are . .

1 Plant Trips (93702)

Following the plant trips on February 26, 1987, and March 1, 1987, the inspectors 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. 1he inspectors verified the establishment of proper communications and reviewed the corrective actions taken by the license The resident inspector and startup team member were in the control room at the time of the February 26, 1987, event observing control room i

activities. The inspectors reviewed immediate operator actions for the reacter scram and post scram recovery action All systems responded as expected, and the plant was returned to operation on February 28 and March 2,1987, respectivel No violations or deviations were identifie . Management Meetings (30702)

On February 23, 1987, NRC Region III met with licensee representatives (noted in paragraph 1) at the Regional Office and presented an enforcement package relating to surveillance issues discussed in Inspection Reports 50-341/87002, 50-341/87006, and 50-341/8700 On February 25, 1987, NRC representatives (Senior Resident Inspector, Region III Deputy Division Director, Region III State Affairs Officer, andanInternationalAffairsrepresentative)participatedina presentation to Canadian public officials at the Fermi 2 Nuclear Operations Center. NRC personnel explained the onsite inspection role, assessment function of the restart inspection team, interaction between the NRC and Canadian government in an emergency. A question and answer period followed.

j 12. Unresolved Items 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 inssectors met with licensee representatives (denoted in paragraph 1)

on Marc 1 5, 1987, and informally throughout the inspection period and summarized the scope and findings of the inspection activities. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licenseu did not identify any such documents / processes as proprietar The licensee acknowledged the findings of the inspectio _ _ _ - - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _. __ . _ _ _ _ _ _ _ _ _