IR 05000341/1992016

Insp Rept 50-341/92-16 on 921026-1117.No Violations Noted. Major Areas Inspected:Review of Concerns Raised in Area of Instrument Loop Calibration,Using Selected Portions of Insp Modules 37701 & 0517A

ML20128C996
Person / Time
Site:	Fermi
Issue date:	11/30/1992
From:	Brush F, Falevits Z, Gardner R, Tella T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128C982	List: IR 05000341/1992016 ML20128C979
References
50-341-92-16, NUDOCS 9212070097
Download: ML20128C996 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/92016(DRS)

Docket No. 50-341 License No. NPF-43 Licensee: The Detroit Edison Compan North Dixie Highway Newport, MI- 48166 Facility Name: Fermi 2 Nuclear Power Station Inspection At': Fermi Site,. Newport, MI 48166 Inspection conducted: October 26 through November 17, 1992 Inspectors: l$~ $ 0 I Tella Date f

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??. T,i lI 2 0 - 9 Z. Falevits Dat /. r - fl~ 3 0- 4b F. Brush Date Approved By: bb h 'W -

R. N. Gardner, Chief

- 'I !3 ' W Date Plant Systems Section Inspection Summary Inspection on October 26 throuch November 17, 1992 (Report N /92016(DRS))

Areas Inspected: Routine unannounced inspection of power uprate modification and review of concerns raised in the area of instrument-loop calibration, using selected portions of inspection modules 37701 and 0517 _

Results: No violations or deviations were-identified during this-inspection. The power uprate program was well implemented through adequate work controls.- Region III concern (AMS N RIII-92-A-0117) was addressed. Two unresolved items were note One-involved the-inadequate review of safety related procedure The second involved the inadequate implementation of a procedure for trending instruments which consistently failed to meet-the as-found acceptance criteri PDR ADOCK 05000341 G PDR

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e QETAILS . Persons Contag,ted Detroit Edison Company (DECO)

• W. Orser, Senior Vice President

• D. Gipson, Vice President, Nuclear Operations

+*R. McKeon, Plant Manager ..

• M. Deora, Project Manager, Power Uprate Project

• L. Goodman, Director, Nuclear Quality Assurance  ;

• A. Kowalczuk, Superintendent, Maintenance

+*R. Mathews, Assistant Superintendent, Maintenance

• W. Miller, Jr., Superintendent, Technical Engineering _

• R. Newkirk, General Director Regulatory Public Affairs-

• R. Russell, Outage Manager

+*A. Settles, Jr., Director, Nuclear Licensing

+*J. Tibal, Supervisor, Compliance

• J. Walker, General Director, Nuclear Engineering U.S. Nuclear Reaulatory commission (NRC)

• W. Kropp, Senior Resident Inspector

• S. Stasek, Senior Resident Inspector, Davis-Besse

+*K. Riemer, Resident Inspector

+R. Twiggs, Resident Inspector The NRC inspectors also contacted and interviewed other licensee employees, as neede * Denotes those present during the onsite exit meeting conducted October 30, 199 + Denotes those participating in the telephone exit meeting on November 17, 199 . Power Ucrate Modification The purpose of the power uprate modification was to increase the reactor power by 4.2 percent to 3430 MWT, thereby increasing the gross electrical output by 46 MWe to 1200 MW The proposed license amendment was submitted to the NRC in September 1991. The operating license amendment was issued in September 1992.__ The inspectors noted'that the power uprate modification in the areas inspected was implemented and tested per the licensee's program, The inspectors reviewed-the licensee's power uprate implementation plan,-proposed license amendment, safety analyses, setpoint changes and supporting calculation The inspectors-also reviewed the licensee's revised

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surveillance-and calibration-procedures, training '

provided to the operations, maintenance and engineering- "

personnel and selected QA-audits and surveillances on-the power uprate progra The inspectors selected seven areas of the modification for a detailed review. These areas included neutron monitoring instrument changes, safety /reliof valve (SRV) setpoint changes, control room instrument scale changes, reactor pressure increase, emergency response information system (ERIS)/ safety parameter display system (SPDS) changes and the electrical modification for a valve installed in RCIC bypass line. The review included engineering design packages, supporting calculations, and the implementation of-the-proposed changes through the surveillance / calibration procedures, and the start up test progra The inspectors observed calibrations being performed and conducted a walkdown of the plant and control room to verify whether the approved changes were properly implemented in the field.

l The inspectors interviewed'various plant personnel,

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including management, engineers, supervisors and technicians. Based on the document reviews, interviews and observed work activities, the inspectors determined that the power uprate modification was well implemented and that the work was controlled through adequate procedures. Post modification testir was completed in accordance with the licensee's uprat program requirement Safetv/ Relief Valve (SRV)-Setpoint Chances The inspectcrs reviewed engineering design package EDP 12559 for SRV-setpoint changes. As a result of the power uprate modification,-the pressure relief setpoint for SRV-B2104F013G was increased to 1135 i 11 psi The SRV installed in this location was refurbished in June 1991, and had been previously set at 1130 i.11 psi Prior to installation, its relief pressures were determined to be 1124, 1125, and 1124 psig,:which:were at the lower limit of the new required rang .

Discussions with licensee operations-personnel. revealed that they had not been informed of the' decision to use a valve with this setting, and this lower SRV setting could have caused a premature lift concern. The inspectors didInot have a regulatory concern with the licensee's decision to use the refurbished SRV; -

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I however, the lack of communications with the operations organization regarding the low setpoint was' considered a weaknes Simulator Training The inspectors reviewed the licensee's revised simulator training of the operations staff for the power uprate modification. The licensee stated that all operators were provided classroom training on the changes to operating conditions caused by the power uprate progra However, the inspectors determined that operaters were not trainad on the simulator for certain uprate conditions such as increased reactor pressure, higher SRV setpoints, and increased steam and feed flows. The licensee stated that the operators were trained on the simulator at 96% of the uprate (new) power level (which is the old 100% level) and that the plant simulator will be updated by February 1993 to incorporate the revised operating condition No violations or deviations were identified in this are . Jnstrument Calibration The inspectors observed the ongoing instrument calibration work in the plant. The inspectors also reviewed the instrument calibration records. The following was noted:

The inspectors observed the recirculation flow transmitter-calibration, as per surveillance procedure No. 44.010.167,

" Flow' Unit D Calibration," Revision 2 During the calibration, on October 28, 1992, the I&C technicians stopped the testing because they could not proceed further due to discrepancies identified in the procedure. For example, process computer point B037 could not be displayed

as per step 6.2.5 of the procedure. The quality engineer accompanying the inspectors also stated that this surveillance procedure (Revision 25) was used on April 14, 1991, when several procedural discrepancies were identified by the I&C technician, including the one mentioned abov Only one of the discrepancies identified in April-1991 was I

picked up in the current revision of the procedure. The licensee proposed to issue.a Deviation Event Report (DER) to identify the root causes for the inadequate review of the three procedure revisions and to implement corrective L action Pending further evaluation and corrective actionc

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by the licensee, this is considered an unresolved item (341/92016-01(DRS)).

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~ (Closed) AMS No. RIII-92-A-0117 - Instrument Loop-Calibration-Practices Conclusion Based on the review of the licensee's current practice of not performing instrument loop functional checks when a loop end device (indicator / recorder) was found to be out-of-tolerance, the inspectors determined that no regulatory requirements or industry-standards were violate However, some weaknesses were noted in the licensee's trending program of instruments that consistently did not meet their specified toleranc The details of the NRC's review are' contained in paragraphs b.(1), (2), and (3) of this repor This concern was substantiated in that the practice of not calibrtting the entire loop occurred; however, the inspectors concluded the practice did not violate any requirements, NRC Review (1) A concern was expressed relative to instrument loop check practices during the implementation of engineering design package EDP-11255. The purpose of the design package was to provide scale color banding and other enhancements for recorders and indicators in the control room and on the remote shutdown panel. The specific concern related to the I&C supervisor's decision not to perform a -

complete instrument loop functional and/or calibration check, when during a functional check of the loop's end device (indicator / recorder), the as-found data was found to be out-of-toleranc To address this concern, the inspectors conducted interviews with various plant personnel, including

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instrumentation and control (I&C) technicians, supervisors, engineers, management and training personne In addition, the inspectors reviewed-portions of EDP 11255, instrument loop-schematics, completed work requests, instrument history folders, instrument trending data, I&C design calculations, completed surveillances and procedures, post maintenance testing, deviation reports and regulatory and industry requirements relative to this issu "An instrument loop (channel) . is an arrangement of components as required to generate an output signal which.may be a proactive signal to control a system or an analeg/ digital display device."

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The I&C technicians interviewed stated that based on past practices, an instrument loop functional check and/or a calibration would be conducted to determine which component in the loop caused the out-of-tolerance condition and whether another component in the loop was potentially compensating for the out-of-tolerance indicato The licensee management's position was that since the end device was the only component being manipulated, the out-of-specification condition would be related only to that end device.

i During this review, the inspectors determined that the only documented requirement addressing loop calibration was specified in procedure NPP-CT1-06,

" Post Maintenance Testing Guidelines," Revision 5, Enclosure The procedure required that a channel (loop) calibration be performed only if replacement of or maintenance on a transmitter sensor, power supply, signal conditioner, isolation module or trip actuating device had occurre The inspectors could not identify any regulatory requirement or industry guidance relative to the performance of loop checks when an i end device is found to be out-of-toleranc {

However, even though not specifically required, the practice of performing a complete loop calibration if the end use device was found out of calibration was considered a good practice and represented a conservative approach to ensuring the complete loop remained in calibration. In addition, on November 2, 1992, Region III staff discussed this issue with NRR staff members. No safety concerns were identifie This concern was substantiated in that the practice of not calibrating the entire loop occurred; however, the inspectors concluded the practice did not violate any requirement (2) During the review of the surveillances and work requests associated with EDP 11255, the inspectors noted that a large number of loop instrumente did not meet the as found specified tolerance on some of the measured parameters. Some of those instruments (e.g., transmitters B21-N484, G33-N603B and G33-N041) failed to meet the as found specifications during several of the most recent loop check The inspectors noted that when the licensee found an instrument outside the acceptable limits, it was adjusted to acceptable value The instrument history cards showed only corrective maintenance but did not indicate any

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drif Also, the as-found drift was not trended by either I&C or engineering group The inspectors noted that during a Safety System Functional Inspection (SSFI) conducted in 1988, the licensee identified that there was no trending program for instrument setpoint calibratio Deviation Event Report (DER) 88-0146 was written on March 3, 1988, and as a result, procedure NPP-CTI-05 was issued to address this deficienc NRC review of the licensee's implementation of procedure NPP-CT1-05, Revision 0, "I&C Surveillance Test Setpoint Trending," indicated that specific criteria for trending requirements were not specified and therefore left open to interpretation by the maintenance supervisor or forema For example, item 6.3.2.4 of the procedure stated that if as-found entries are consistently "NO" (i.e., out-of-tolerance), notify the General Supervisor-I&C. A specific criteria for the number of out-of-tolerance instm ;ck needed to initiate a DER was not specif ed in the procedure and individual instruments were .ot being trended when they consistently failed to meet the specified as-found tolerance In addition, loop trending data recorded on Attachments 1 and 2 of the procedure was ambiguous, incomplete and inconsistent with the data previously obtained during the performance of the applicable surveillances. For example, in the

" Tech Spec Satisfied" column, some of the As-Found entries were noted "YES" when they should have been noted "NO". This incorrect data would yield incorrect trending results and evaluation Relative to trending requirements, Fermi Management Directive Procedure FMD-CT1, Revision 3, " Calibration, Testing and Surveillance," stated that equipment and systems that fail to meet as-found acceptance criteria shall be trended in accordance with procedure FMD MA No evidence that this has been accomplished was available for revie The inspectors determined that instruments which consistently failed to meet the specified tolerances were not trende In addition, the root causes for instruments that consistently failed to meet specified tolerances had not been determined by the licensee. Pending licensee action and further NRC review, this is considered to be an unresolved item (341/92016-02(DRS)).

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(3) The inspectors noted that for the-components identified as not meeting the specified tolerances, the Technical Specification trip setpoint limits were not reached. Consequently, no Technical Specification requirements were violated. A review of design calculations (DCs 4523, 4525, 4527 and 4608) indicated that a conservative approach was utilized in identifying the component calibration tolerances-used to meet the Technical Specification requirements. This conservative approach could have been a

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contributing factor to the. number of surveillance procedure components that were identified as out-of-toleranc For example, Design Calculation 4 4527, "MSIVLCS Surveillance Procedure Validation," >

Revision A, Channel Instrument Error, used only the vendor stated accuracy and did not include additional allowances (e.g., vendor stated drift, drift temperature effect and M&TE errors). In addition, on October 13, 1992, during the performance of surveillance 44.020,152, I&C technicians experienced difficulties in adjusting the G33-N041 loop instruments to obtain acceptable data for process inputs from the flow transmitter and the square root converter. The as-found reading for this loop was found to be out of the allowable tolerance. DER 92-0561 was issued to address this concern. Nuclear engineering evaluated this problem and determined that the tolerances for loops G33-N041, G33-N012 and G33-NO36 had to be changed so.that they could be mo The licensee stated that additional evaluations of instrument loop tolerances would be performe During review of I&C calculations, the inspectors also identified some minor calculation errors in the I&C instrument calibration _ calculations, but these errors were determined not to have any safety significanc No violations or deviations were identified in this are . Unresolved Items Unresolved items are matters about which more information is-required in order to ascertain whether they are acceptable items, violations or deviations. Two unresolved items disclosed during this inspection are discussed in_ Paragraphs 3. and 4.b.(2)'of this repor _

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• G. Byit_Rqqtjltg The inspectors met with licensee representatives (denoted in Paragraph 1) on October 30, 1992. The inspectors also held a telephone exit on November 17, 1992, after the conclusion of further reviews by the NRC staff. The inspectors summarized the scope and findings of the inspection activities. The licensee acknowledged the inspection finding The inspectors also discussed the likely informational content of the inspection report with regard to documents or' processes reviewed by the inspector during the inspectio The licensee did not identify any such document / processes as proprietary.

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