IR 05000341/1997016

Insp Rept 50-341/97-16 on 981108-0105.Noncited Violation Identified.Major Areas Inspected:License Operations,Maint, Engineering & Plant Support

ML20202F998
Person / Time
Site:	Fermi
Issue date:	02/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202F982	List: IR 05000341/1997016 ML20202F977
References
50-341-97-16, NUDOCS 9802200035
Download: ML20202F998 (22)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli

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Docket No: 50 341 License No: NPF 43 Report No: 50 341/97016(DRP)

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Licensee: Detroit Edison Company (DECO)

Facility: Enrico Fermi, Unit 2 Location: 6400 N. Dixie Hwy, Newport, MI 48166 Dates: November 8,1997, through January 5,1998 Inspectors: G. Harris, Senior Resident inspector C. O'Keefe, Resident inspector A. Kugler, Project Manager, NRR Approved by: Bruce L Burgess, Chief Reactor Projects Branch 6

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EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC Inspection Report No. 50 341/97016(DRP)

This inspection included espects of licensee operations, engineering, maintenance, and plant support. The report covers an eight week period of resident inspectio Operations

• The inspectors concluded that, in general, the operators performed well during this -

Inspection period, High visibility operations were well coordinated and conducted; however, two procedural weaknesses were identified; one that delayed identification of the loss of the process computer by the operators and the other that could potentially result in missed commitments due to changes to operator round sheets. (Section 01.1)

e The licensee promptly identified two safety tagging errors and took appropriate immediate actions. The inspectors concluded that each event had minimal safety significance. However, the inspectors were concemed that multiple barriers designed to make safety tagging error free were rendered ineffecilve by operator practices. The licensee's corrective actions included a human performance rey!ew day for all site personnel that included a detailed review of the safety tagging errors (Section 01.2),

o The inspectors concluded that power uprate testing was conducted in a coordinated manner. However, the determination of plant response at higher power levels was limited in scope. The inspectors concluded that by not performing a detailed plant walkdown, unanticipated changes in plant conditions may have been missed (Section O2.2).

Maintenance e Two personnel errors were promptly investigated and corrective actions implemente The licensee's planned corrective action included a comprehensive assessment and review of the two events during a human performance leview day, which will include all station personnel. Neither error was safety significant, but these events indicated a continuing trend in personnel errors during maintenance activities previously documented in inspection Report No. 50 341/97013 (Section M1.2).

• The inspectors concluded that the accepted practice of disregarding gauge use restriction labels auld potentially result in the introduction of foreign materialinto plant systems. Also, the use of the data from an imprecise gauge reading resulted in measurements that were close to the alert range of the Division 2 Emergancy Equipment Cooling Water pump. The alert range testing would result in increased unnecessary testing and equipment wear. The inspectors concluded that lack of a questioning attitude and training contributed to the event (Section M1.3).

• In general, the freeze protection program was adequately implemented; however,

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system design and equipment deficiencies in the turbine building ventilation and reactor building ventilation syctem continued to challenge operators (Section M2.1).

Engineering e The inspectors concluded that the licensee did not process the 10 CFR 21 notice concerning Asea Brown Boveria K Line breakers in a timely manner. This delayed an operability evaluation of breakers which were associated with multiple safety components. The inspectors were concerned that an adequate avaluation of the use of cross tie breakers was not performed prior to using maintenance crosstle breakers to supply power to Residual Heat Removal service water crosstle valves. Two unresolved items were identified pending review by the licensee (Section E2.2).

Plant Suocort e The inspectors concluded that the licensee performed appropriate surveys following changes in plant conditions, such as starting up the hydrogen water chemistry syste However, general area survey maps were not superseced when conditions on a portion of the map changed. It was not always clear that additional survey maps needed to be reviewed (Section R3.1).

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Report Details Summary of Plant Status With the following exceptions, Unit 2 operated throughout this inspection period at 96 percent power,

• On November 17,1997, power was incrementally raised to 93.6 percent to support -

power uprate testing. Power was retumed to 96 parcent when the turbine control valves

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appeared to be operationally limite * During the weekend of December 1314,1997, power was reduced to 65 percent in order to perform periodic turbine valve testing.

, e On December 29,1997, power was reduced to 25 percent in order to repair a feedwater controller, Power was retumed to 96 percent on December 31,199 l. Operations 01 Conduct of Operations 01,1 Ofngial Comments Inspection Scope f71701)

The inspectors conducted frequent control room observF 1s during power uprate testing, the scheduled power reduction for turbine valve is 'ng and rod pattem adjustment, and an unscheduled power reduction to make repairs to a feedwater controller, in addition, the inspectors reviewed logs and other ccotrol room document Specific comments and noteworthy observations are discussed below, Qbservations and Findinas Operations continued to exhibit overall improvement. High visibility operations, such as power uprate testing (discussed in Section O2.2), were conducted in a coordinated manner, Of specific note were the operators' actions following the identification of a feedwater controller anomaly, e On December 29,1997, operators identified a feedwater controller anomaly and obtained assistance from support organizations. The licensee acted promptly to reduce power below 25 percent in order to remove the affected controller from service and avoid challenging the plant. The inspectors noted that the operators worked as a team and displayed a questioning attitude during the pov/er reduction and the subsequent return to full power. Shift supervisory nernonnel were fully involved in the power level changes and raenforced management expectations for operator performance. Even with the emergent nature of the power reduction, the inspectors noted that operations management scheduled simulator sessions for the~ operating crews which emphasized operating the plant with abnormal feedwater control alignments.

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In contrast to the performance associated with the feedwater controller snomaly, the i inspectors noted that personnel performance errors continue to occur during routine l operations (discussed in Section 01.2). In addition, the inspectors noted two instances of procedural weaknesses. The licensee did not have procedures which directed operator response in the event that the process computer failed, and the non licensed operator rounds sheets were revised without receiving management or engineering ,,

review * The inspectors reviewed control room logs and noted that the process computer system, on numerous occasions during the inspection period, did not function properly. One failure mode did not result in any alarms, such that failures were recognized only when the licensee noted that the plant specific indications were not periodically updated. A significant period could elapse before discovery of the failure. The inspectors questioned operations personnel and determined that they were not aware of specific actions for loss of the process computer during all modes of operation including while shutdown. The inspectors concluded that the lack of procedures and specific training did not ensure a consistent approach and appropriate response to the loss of the plant process computer function during all modes of operatio * The inspectors identified that operator round sheets were changed significantly when rounds were adjusted from every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Changes were made without proper reviews, including safety evaluations. The inspectors discussed this concem with station management who agreed that additional procedural control measures were appropriate. The inspectors concluded that the lack of adequate procedural controls for operator round sheets could result in missing commitments or introducing other problems, c. Conclusion 1 The inspectors concluded that, in general, the operators performed well during this inspection period. High visibility operations were well coordinated and conducted; however, two procedural weaknesses were identified; one that delayed identification of the loss of the process computer by operators and the other that could potentially result in missed commitments due to changes to the operator round sheets.

01.2 Operator Performance issues inspection Scope (71707. 92901)

The inspectors conducted an independent review of the licensee's root cause determination and corrective actions following two safety tagging errors. Operations personnel were interviewed, and tagging instructions and documents were reviewed and walked down in the plan .. __ . _ _ . _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ - --

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I F onnarvations and Finenes L

j Randor Water samale Point inadvertentiv isolated  !

! On November 26,1997, while clearing tags following a modifloation to the sample sink i flow indicators, a non licensed operator inadvertently dropped a safety tag that could not i

be readily retrieved. Following modifications to the romaning flow indicators, another

non licensed operstor discovered the lost tag, rehung N, and closed the assoolated valve.

! This resoled in securing flow to the in service continuous reactor coolant conductivity ,

monitor tnat was required by Technical specifications (Ts), specifically, surveillance  ;

Requirement 4.4.4.c, required a continuous recording of reactor coolant conductivity. The j

error was identifled about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later, and the esmple point was then restored promptl ;

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Corrective actions included measuring reactor coolant conductivity and addressing

! human performance errors by conducting a human performance toview day. Reactor j ooolard conductivity was determined to be within the TS limit ,

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. . . i l While in operation Condluons 1,2, and 3, T8 4.4.4.c required, in part, that an in-line i 4 conductivity measurement be otdained at least once per every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> when the  !

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continuous recording conductivity monitor was (noperable. The failure to obtain en in-line j j conductivity messerement within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was a violation of TS 4.4,4.c. This non-  !

repetitive, licensee locntified and corrected violation is being treated as a Non-CNed 6

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Violation (NCV), consistent with section Vll.8.1 of the NRC Enforcement Policy . L i (NCV 50 341/g7016 01).  ;

{ ' b.2 ' Switchward Breaker Air Bucolv Inadvertentiv laolated On Dooomber 17,1997, a non-lloonsed operator was briefed on cross-tying the air  !

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systems for two 346 kV swHohyard breakers. No procedure existed for this evolutio i The inspectors concluded that the tagout was correct, but N was prepared from a i

previously used tagout because no prints existed. The tagout was hung incorrectly

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component labels, Both the shift foreman and the maintenance supervisor incorrectly

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!.  ; described the valve to be operated, and the operator posMioned the valve based on this

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) Maintenance was to be performed on the *DF" breaker compressor, so air was to be i supplied to the *DF' breaker air system led the "CT' breaker compressor, The operator i

perf. rmed the lineup as briefod, then left the switchyard. Two hours later, after a shift  !

- tumover, but before the tags were second-checked, the low pressure alarm was received - ,

for the "DF' breaker air system. The operator responding to the switchyard determined o that the air reservoir had been isolated from the breaker instead of the compressor being  !

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Isolated from the reservoir. Thus, the *DF' breaker had no air supply. _ By design, loss of '

L- air pressure would cause the breaker to open before pressure became too low to operate the breaker. Operators cleared the tags and restored the normal lineu j b.3 ' Ownership of Switchyard Eaulomont 4 i

While investigating the breaker control air system tagging error, the inspectors noted that

a lack of ownership of switchyard equipment continued to hist. This was previously

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documented in inspection Reports Nos. 50 341/96016 and 50 341/97002. On i

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January 1/,1997, the CM breaker failed, resulting in motorizing the main generator due to lack of adequate operating instructions for and training on switching operations. On February 3,1997, a switching order was received for restoration of bus 302 which forms part of the 345 kV switchyard. An operator inappropriately closed a knife switch, resulting in tripping the CM and CF breakers. Ownership was lacking in that operators continued to accept a lower standard of available documentation, equipment labeling, and training related to the switchyard equipment than for regular plant equipment. The inspectors !

concluded that this was not a 10 CFR 50, Appendix B, Criterion XVI violation, however, t because these two earlier events involved non safety related systems. Additionally, the consequences of both events were minima Conclusions The licensve promptly identified two safety tagging errors and took appropriate immediate actions. The inspectors concluded that each event had minimal safety significanc However, the inspectors were concerned that multiple barriers designed to make safety tagging error free were rendered ineffective by op,$rator practices. The licensee's corroctive actions included a human perior. nance review day for all site personnel that included a detailed review of the safety tagging errer Operational Status of Facilities and Equipment 02.1 SAffty System Walkdowns (71707) j The inspectors used inspection Procedure 71707 to walk down accessible portions of the following safety related systems; e Standby Gas Treatment System, Divisions 1 and 2 e Combus'. son Turbine Generator No.11 1 e Emergancy Equipment Cooling Water System, Division 2 e Ememency Diesel Generator No.12 e Core Spray System o Residuai Heat Hemoval System Equipment operability, material condition, and housekeeping were acceptable in all cases. Several minor discrepancies were brought to the licensee's attention and were .

corrected. The inspectors identified no substantive concerns as a result of these walkdown .2 Power Vorste Testina Inspection Scope (71707)

The licensee resumed static power uprate testing on November 17,1997. Power uprate had been approved in a licens6 change in 1992 and modifications based on earlier test results had been installed following the previous two operating cycles. The inspectors reviewed Infrequently Performed Test / Evolution (IPTE) 97 04 and Sequence of Events (SOE) Test 97 09 for continuing power uprate testing. The inspectors also observed power increases and conducted plant walkdowns to determine if any plant changes occurred as a result of the power levelincrease ..

_ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - Observations and F10dIDQ1 During testing, the licensee was able to in:,rease power to 98.0 percent before the tutt>lne control valves lost effectiveness. Power was then reduced back to 96 percent in accordance with the SOE. The inspectors observed good coordination and planning during this evolution. Licensee management was fully involved, and each power level increase was approved only after appropriate review During operation with power abova 96 percent, the inspectors conducted walkdowns of the plant to identify changes to affected equipment. During an independent walkdown of the plant, the inspectors identified a number of issues to the senior line manager in charge of the test:

• A support collar for the main lube oil supply line to Generator Bearing No.10 was contacting ar.d being moved by a 1% inch hydrogen seal oil drain line. The drain line had lost metal along a 1 inch section.

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• The No. 3 Jacking Oil Pump supply line guard pipe was vibrating excessivel The closest support was found to be slack, but after tightening, the vibration was not completely corrected. The final vibration was determined by engineering personnel to be acceptable, but the licensee planned to correct this condition during the next scheduled outag * Pipe movement was observed in the south reactor feed pump turbine main steam l line and the reactor core isolation cooling (RCIC) steam inlet line. The licenseo l determined that this was expected and acceptable based on observed and evaluated movement at lower power level * The licensee was unable to observe the reactor building steam tunnel because this locked high radiation area had cameras which were unusable. One of the cameras was subsequently replace The inspectors also noted that SOE 97 09 did not require plant walkdowns. The licensee promptly documented and resolved the issues identified by the inspectors. These issues were discussed by the Onsite Review Organization (OSRO) as part of the power uprate testing review before increasing power. The licensee planned to evaluate the test results and consider what additional testing would be required to operate the rest of the current cycle at 98 percent powe Conclusion _3 The inspectors concluded that power uprate testing was conducted in a coordinated manner. However, the determination of plant response at higher power levels was limited in scope. The inspectors concluded that by not performing a detailed plant walkdown, unanticipated changes in plant conditions may have been misse )

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11. Maintenance  !

M1 Conduct of Maintenance M1.1 general Commer% poection Scoos Q1MZ)

The inspectors observed all or portions of the following work activities: -

e Average power range monitor gain adjustments e Combustion Turbino Generator No.11 1 surveillance run e Emergency equipment cooling water system pump and valve operability surveillance e Local power range monitor calibrations '

e Control rod operability surveillance testing e Insdiated fuel inspect!on activities -

e Division 1 control center heating, ventilation, and air conditioning outage work e Replacemer,t of radwaste ultraviolet light unit e General serv ce water de lce sequence of events test 971 e JM pump operabill'y surveillance testing e Seismic fronitor surve;llance testing

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e Emergency d;esel generator surveillance testing o Reactor core isolation cooling system surveillance testing e Non interruptibls Air System outage work e Feedwater controller troubleshooting and repair , Observatlens and Findinos The inspectors observed that these activities were performed in a professional and thorough manner. All wu t observed was performed with the work package present and in use as appropriata, and technicians were knowledgeable ofi..elr assigned tasks. The i inspectors obser>ed that maintenance workers and component engineers worked effectively with system engineers and operations personnel to troubleshoot and repair the feedwater controller in an expsd;tious manner. Maintenance perronnel effectively planned activities, minimizing the time that the feedwater controller was inoperabl ' However, some routine maintenance activities challenged the licensec, as discussed below in Section M1.2,

, Conclusion!

The inspectors concluded that the conduct of maintenance activities performed at the

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station during the inspection periud was generally adequate. This was evident in the timely troubleshooting and repair during an emergent feedwater controller failure.

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j M1.2 Maineananon Performanos laaues

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. Inamedian Banas (62707) ,

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Earty in December, igg 7, two signif6 cant personnel errors occurred during the j

performance of maintenance activl'.ies. The inspectors independently reviewed the  ;

circumstances surrounding these errors and the licensee's corrective actions resulting l

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i b,1 Unamoncied Hall Turbina Trio caused by Cannecting Multimeter in Wrong Mode -!

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On December 8, igg 7, instrumentation and Control (l&C) technicians were performing  :

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Proventive Maintenanos Event 1228gg0g00 to calibrate a main steam reheater low steam -  ;

- pressure switch. When the multimeter was connected to the circuit, an unempeoled half i tuttnne trip was reoelved (i.e., half of the turbine trip logic was satisfied, but no trip j ocourred). The technicians then rooognized that the meter was in the resistance 1 L

- measuring mode, which shorted the contacts being measured. This ermr was not noted l during setup because the test equipment was a new Fluke 47 which had gone into the .;

battery sever mode, blanking the display in the same manner that tuming the motor off ,

would produce ' The meter was thought by workers to be off because the screen was

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blan Applicable maintenanos groups conducted training on this event, stressing'self-checking g and the features of the new meters.: The inspectors determined that this event had no safety significanc ,

! fire in Load Test Bank Due to Connectina to Soare Batterv in Wrona Confleuration

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- On Dooomber g, igg 7, a capaolty test for a new battery, planned to be installed as the replacement for one of the balance of plant batteries, was conducted. When the test was

. started, a fire began in the load bank. The fire brigade was not activated due to the brief  ;

duration of the fire. The licensee conducted a thorough investigation, and determined  ;

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that the workers did not connect the load bank in the high voltage configuration, instead, i the workers had instal:ed N in the same low voltage configuration which was used during i previous testing, contrary to the work instructions. This resulted in twice the exceoted  ;

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- current, damaging the load bank. The licensee concluded that this event was caused by lack of self checking and supervisory oversight and incomplete tumover between shifts.- ,

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iThe inspectors determined that, due to the brief duration of the fire, this event was of

. minor safety significance. Also, because the load bank was non safety-related, the -i inspectors determined that rio violation of NRC requirements occurre '

l Each of the events was scheduled to be discussed during site wide personnel l

performance meetings on January 15,199 j E Conclusions Two personnel errors were prompt ly investigated and corrective actions implemented, j i

The licensee's planned corrective action included a comprehensive assessment and

review of the two events during a human perfom)ance review day which willinclude all  !

station personnele Neither error was safety significant, but these events indicated a  ;

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continuing trend in personnel errors during maintenance activities previously documented in inspection Report No. 50-341/97013.

M1.3 Division II Emerotnev Eculoment Coolina Water System Surveillance Inspection Scope (01726)

The inspectors reviewed TSs, Emergency Equipment Cooling Water pump performance data, UFSAR, Condition Assessment Resolution Documents (CARDS), administrative and technical procedures; and interviewed instrumentation and control personnel, metrology personnel, system engineering and in service testing personnel, Observations and Findinas The inspectors observed a quarterly in service test on the Division 2 Emergency Equipment Cooling Water pump. A temporary gauge installed to measure pump suction pressure, labeled, "For gas use only," was installed in a water system. The inspectors determined that the use restriction label was intended to prevent the introduction of foreign materialinto plant systems. Metrology laboratory personnel stated that using a gauge in this manner was an accepted work practic The inspectors observed that the same test gauge oscillated approximately 3 4 psi (pounds per square inch) on a 16 psi scale, making it difficult for operators to obtain an accurats reading. However, operators made no ttlempt to dampen the oscillations. The inspectors determined through discussions with operators and the system engineer that the observed oscillations were greater than expected. In discussions with the inspectors, station management acknowledged that action shouid have been taken to dampen the gauge indication and operator training would be conducted to define expectations and acceptable actions in this regar The inspectors reviewed the test results and noted that the pressure value obtained was close to the alert range for the pump. Placing the pump in the alert range could have resulted in unnecessary pump testing and wear. The results of previous testing had indicated no adverse trend in pump performance; therefore, the inspectors concluded that system operability was not degraded, Conclusio01 The inspectors concluded that the accepted practice of disregarding gauge use restriction labels could potentially result in the introduction of foreign materialinto plant system Also, the use of the data from an imprecise gauge reading resulted in measurements that were dose to the alert range of the Division 2 Emergency Equipment Cooling Water pump. The alert range testing would result in increased unnecessary testing and equipment wear. The inspectors concluded that lack of a questioning attitude and training contributed to the event,

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I li = M2 Maintonense and Matettal Condillon of Faellities and Equipment f

, M2.1 franza Pmtaden Pmaram implementation j

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Insmedian Bonne (71714)

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j . The inspectors reviewed surveillance and opMational procedures, conducted walkdowns

of selected areas of the plant, reviewed Condition Assessment Resolution Documents =

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(CARDS), TS requeroments, UFSAR, and held discussions with operations and system '!

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engineering personnel, j

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observations and Findinas The inspectors assessed the licensee's implomontation of ooid weather protection  !

measures. The measures included implomonting surveillance and monthly operational i procedures. The inspectors reviewed the implementation procedures and observed >

l walkdowns of the plant using them. The inspectors determined that the wakdowns were i performed in a satisfactory manner and that all discrepancies noted were documented in ,

. the corrective action system. The inspectors noted some minor procedural issues, i~ however, these were promptly recorded in the corrective action syste i

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I Corrective actions from previous problems identitled during implementation of cold ,

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weather protection measures were reviewed and were adequately implemented. The  ;

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inspectors noted that the licensee had increased the setpoint of the condensate storage ~!

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tank instrumentation cabinet temperature alarm to provide additional woming to .

operators, prior to a freezing event. Freezing of this instrumentation had occurred on at

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least two ooossions resulting in inoperability of safety-related component ,

in addition, the inspectors noted repeated trips of turbine building and reactor building ventilation systems. In the case of reactor building ventilation, ventilation trips challenged ,

o the standby gas treatment system, which was required to automatically start to maintain

secondary containment integrity, As in past winters, both systems had to be operated l 4 with manual control of steam heating, and operators had to maintain olevated

- temperatures in both buildings to avoid system trips. Multiple attempts to restari the l

reactor building ventilation system included one instance observed by the inspectors in l which it took operators almost 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to restore reactor building ventilation following a i

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- ci Conclusions

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i ln general, the freeze protection program was ' adequately iM ilemented.- However, system design and equipment deficiencies in the turbine bunding ventilation and reactor 4 building vent 6lation system continued to challenge operator . .

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- M Miaoellaneous Maintenance issues (92902)

- M8.1 (Closed) Follow Up item 50-341/95006-01: Combustion turbine generator (CTO) 11 1

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- deficiencies not all in work system. During the recently completed CTG 11 1 refurbishment, the licensee thoroughly evaluated the existing condition of the system and ,

t its preventive maintenance program. The inspectors discussed the system status with

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the system engineers and operators and compared the few noted deflaiencies with those . l documented in the work control system and identified no disoropancies, The inspectors ;

noted that no backlog of work existed for CTO 11 1 Additionally, the licensee changed the work process for the offsite personnel who perform CTO maintenance such that the !

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Fermi work control system was used for all CTO work. This item is close MS.2 (CinandLViolation 10 341/96002 09: Motor operated actuator separated from turbine '

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steam draln valve, The 16consoe investigated the failure of the four bolts which secured the actuator to the valve. Metallurgical analysis indicated high cycle fatigue was the l failure mode. Following the failure, the licensee installed cameras in this normally t inaccessible room and identified that the four steam drain lines were vibrating excessively ;

due to turbine steam line vibration. The licensee installed viscosity dampers on the i turbine steam lines, which effectively reduced vibration in both sets of pipes. The -

inspoolors confirmed this visually throug5 observations of the pipes using cameras during )

various plant operating conditions. No repeat failures ooourred. This item is close i M8.3 (Closed) Violation 50 341/95012-02a: Inadequate procedures for testing safety-related i battery chargers. Corrective actions for this violation will be reviewed under subsequent Violation No. 50 341/96010-03 for inadequate corrective actions which led to a repeat i problem. This item is closed,

M8.4 (Closed) Violation 50 341/97003 05: Procedure ina:$ equate to install fully charged and tested battery cells. The licensee recently performed Work Request 000Z972712 to prepare a balance of plant batt6ty for installation. The inspectors reviewed the work i documentation for that job and discussed corrective actions for the inadequate procedure with electrical maintenance supervisors; The licensee prepared a new procedure to ,

cover the battery preparation, capacity testing and charging steps. During the first use of i'

the new procedure, a personnel error in lining up the equipment resulted in a load bank fire; however, the inspectors concluded that the procedure was adequate. The load bank fire is discussed above in Section M1.2, Corrective actions for the violation appeared

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adequate.' This item is closed  ;

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E2 . Engineering Support of Faollities and Equipment (92g02) l E Prompt Licensee Response to Industry Report of T-Dra'n Problem Inspection Scope (92903.92903)

? The inspectors reviewed CARD 9714065, Engineering Functional Analysis97-005, and Generic Letters 91 18 and 88 07. The licensee's conclusions and evaluations were discussed with maintenance and engineering personne b, Observations and Findinas The licensee was prompt in initiating an investigation concoming Improperly -

manufactured T-drain plugs in motor operated valves (MOVs). For MOVs inside primary containment or the reactor building steam tunnel T drains protected MOV limit switch

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compartments from overpressure and allowed any condensed liquid to drain out so as not to impact valve operability Lloonsee personnel wrote CARD 9714066 to document this issue and conducted an operability evaluation for MOVs with installed Tairains that were Imoroperty manufacture The licensee promptly identified 21 valves of conoom and determined the safety function of each valve. The vendor was able to provide sufflolerd environmental quali6 cation test data to support the conclusion that the affected valves were capable of fulfilling their intended safety function even if defective T. drains were installe Conclusions The licensee was prompt in assessing this industry issue, identifying the equipment of concem, and making an operability determinat6oa for a condition that affected multiple safety systems,

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E Slow Licensee Response to industrv Breaker Problem a, inspection Scope (92903. 92902)

During a review of deviation event reports, the inspectors noted that a 10 CFR 21 notification (notification) had been issued for a problem identified in Ases Brown Bove ia (ABB) K Line lereakers. The inspectors reviewed the Updated Final Safety Analysis Report, technical documentation, and TSs, Additionally, the notification was discussed with personnel from maintenance, engineering, quality assurance, operations, and the vendor. The inspectors also reviewed Deviation Event Report 971143 and breaker installation test data.

4 Observations and Rndinas  ;

The notification was issued on April 24,1997, following the inadvertent trip of a safety- r

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- related K Line series 600 breaker at another nuclear facility. The cause of the trip was

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attributed to a crossed wire in the overcurrent sensor. This wirbg error caused the trip !

! unit to sense a falso high current condition, tripping the breaker at 50 percent of the l breaker trip setting. The licensee identified that ABB K Line 600 series breakers had ;

been installed at Fermi in both safety-related and non-safety-related applications, ;

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The inspectors noted that the notification was ortginally issued in late April 1997, but due

.to a mailing error (the notification was received by the wrong individual within Detroit -

Edison), station personnel became aware of the issue during a routine quality assurance'

" audit 6 weeks later, on June 9,1997. Station procedures required spedfic actions within ;

10 days to determine the applicability of the issue. However, these actions were not completed until July 22,1997. Additional delays were attributed to problem scope definition and the time needed to complete an operability assessment. Quality assurance - ,

( personnel later reported that two additional 10 CFR 21 notices from the same vendor I

were not received. The licensee's receipt and disposition of 10 CFR 21 notices are -

considered an unresolved item pending a review of the significance and circumstances ;

surrounding the ad6;tional two late 10 CFR 21 notices identified by the licensee

' (URI 50 341/97016-02).

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! The inspectors were conoemeo that the licensee did not initially determine the scope of !

the Part 21 evaluation to include all of the potentially afftetod breakers. After discussing !

Sis conoom with the l6censee, engineering personnel increased the scope of the  !

l evaluation. The licensee's engineering staff determined that some s.dditional plant !

. breakers may be degraded, requiring additional evaluation, inspection and testing. These !

Included 480 volt maintenance crosstle breaker !

1 l Operations management issued a night ortier indicating that the maintenance crosstle of !

breakers be used only to satisfyT8 operability requiremontr. In modes 4 and 6. When i

operators used maintenance crosstie breaker 72ED without declaring the associated load i

E1150 F6028 (Residual Heat Removal service water crosstie valve) inoperable on i

October 12,1997, the inspectors questioned whether the degraded tie breaker was l ospable of providing reliable power to the Residual Heat Removal service water crosotie valve. The inspectors concluded that the licensee did not adequately evaluate the use of !

! crosstle breakers prior to supplying power to a safety-related load.- Through discussions 1

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with engineering and operations personnel, the inspectors concluded t%t the licensee l

, had not adequately considered the impact of the degraded condition in the operability !

determinatio l

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Maintenance and engineering personnel determined through loading analyses, past test !

results, and the use of subsequent wiring controls that there was a high level of :

i confidence that all breaners had the correct wiring configurations. The inspectors !

i re'. lowed appropriate documentation and agrood with the licensee's conclusion. The !

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licensee was developing a new procedure to test and verify the correct configuration of !

l the affected breakers on a periodic basis. However, the inspectors were concemed that ,

( new breakers and breakers refurbished by outside vendors may not have received this '

f testing, in response to the inspectors' conooms, the licensee identiflod two breakers -

U whloh required additional inspection and testing. This issue is considered an unresolved ;

item ptnding the inspectors' review of the results from the additional testing and - r

inspection of the 480 voit breakers (URI 50 341/g7016-03). ,

!

i- - in December 1997, the lioonae conducted an extensive lessons loamed discussion on 1 i the issue of 10 CFR 21 notices and resultant operability determinations. The licensee - ,

r simplified the process for evaluating and dispositioning vendor and 10 CFR 21 notices !

and any resultant operability determinations. The licensee's corrective actions also :

included the following: i l e The new Condition Assessment Resolution Document (CARD) process repleood the existing process for reporting deficiencie '

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e Communication expectations between engineering and operations personnel were i established to ensure the timeliness of operability determinations, l

- e' Current mailing information for 10 CFR 21 notices was sont to vendors.

{ .

_e l Quality Assurance suppliers were advised to confirm receipt of all 10 CFR 21

.  : notices, t

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i c. Conclusions '

The inspectors concluded that a. ncensee did not process the 10 CFR 21 notico concoming Asea Brown Boveria K Line breakers in a timely manner. This dslayed a operability evaluation of breakert, which were associated with multiple safety components. The inspectors were concemed that an adequate evaluauon of the use of i crosstie breakers was not performed prior to supplying power to the Residual Heat ,

Ron. oval service water crosstie valve,s. Two unresolved items were identified pending ,

review by the licensee.

Et Miscellaneous Engineering lasues (92902)

E fClosed) Licensee Event Report 50 341/97010: High Pressure Coolant injection (HPCI)

auxiliary oil pump failed to run on turbine coastdown. Operators noted that the auxiliary oil pump cycled several times then stopped, which was followed by the receipt of an oil low pressure alarm. The operator was able to reset and run the pum ~

The system engineering investigation determined that the seal in contacts which maintained the auxiliary oil pump energized after starting had failed. As a result, the pump was inoperable, rendering the HPCI system inoperable. The pressure switch and the seal in contacts were replaced, and the system was successfully tested without problem recurrence, Oil analyses and vibration data indicated that the system was not damage System engineering personnel also identified that the oil pressure switch which started ,

the auxiliary oil pump on decreasing pressure during turbine coastdown was out of tolerance such ' hat the pump started at a higher pressure than designed. The oil pressure increase from having both the shaft driven pump and the auxiliary oil pump running apparently caused the auxiliary oil pump pressure switch to reset repeatedly during turbine coastdown. The switch was recalibrate The apectors reviewed the auxiliary oil pump control circuit and pressure switch calibration data with the system engineers and concluded that the licensee's actions were appropriate. This item is closed.

E (Open) Inspection Followuc item (IFI) 50 341/95012 07: Combustion Turbine Generator (CTG) 11 1 reliability problems. The licensee conducted a second reliability improvement program for CTG 11 1 during the Fall of 1997. This was necessary because reliability had not improved after the 1996 refurbishment. The licensee worked with the vendor to evaluate in detail all historical problems and identify potential additional failure modes due to aging. A number of components were replaced and additional preventive maintenance tasks were created, Also, problems with spurious diagnostic alarms were corrected through a combination of software and hardware changes. During November, the licensee conducted a series of 50 consecutive system runs, at the rate of one per shift, to demonstrate reliability before returning the unit to service. All 50 runs were successful and the unit was returned to service. The results improved the calculated reliability to about 94 percent for the last 100 starts. However, the system remained a Maintenance Rule (a)(1) category system. This IFl will remain open pending inspector assessment of CTG 11 1 reliability after additional service time of the uni _ _ _ _ _ - __ _ _ . _

E8.3 (Closed) Inspection Followuo item 50-341/96004-08: Multiple reactor water sample system flow glass failures. The licensee installed armored flow meters in the affected sample sink during the week of Novembe 24,1997. Other nuclear plants which use identical, armored flow meters have not ( r cried any operational performance problem Since installation at Fermi, no problems vr.o the armored flow meters were encountere Previous corrective actions regarding improved procedures to avoid flow resonance while placing a sample point in service remained in effect to avoid challenging the syste Corrective actions appeared adequate to prevent recurrence based on available industry experience, but the licensee was unable to determina the exact cause of pipe resonanc This item is close E8.4 (Closed) Inspection Followuo item 50-341/96003-03: Control center heating, ventilation and air conditioning system design criteria, in a letter to the licensee dated August 22,1997, the NRC stated that the licensee had adequately ar essed NRC concems about the Fermi 2 control center heating, ventilation, and air conditioning structural integrity. That letter also stated that the system seismic qualification documentation was acceptable and in accordance with commitments in the updated final safety analysis report. Based on these findings, this item is close IV. Plant Support R2 Status of Reactor Protection and Chemistry Facilities and Equipment R2.1 Miscellaneous Material Condition observations The inspectors noted that a double door to the turbine building decontamination room had a deficiency tag (CARD 97-08443) describing a latching problem. The door was left open as a result. However, a handwritten sign on the door stated that the door was to be kept

shut to prevent ventilation trips. The inspectors questioned the source of tne handwritten sign and the impact of having no ventilation running during work in the decontamination room. The licensee was unable to determine the source of the sign. Work on material likely to create airborne contamination was performed in negative ventilation hoods, so the norrral ventilation system was not required for contamination control. Even though there was no impact on work performance, the inspectors considered it a poor work practice to disregard signs posted in the plant. Also, posting of informal, unapproved signs was a weaknes The inspectors walked down several normally inaccessible areas of the plant while power was low. The inspectors identified two electrical terminal boxes, one associated with each reactor feed pump turbine, which were dripping oil. Also, an emergenc level control valve actuator for a separator seal tank had the handwheel fall off. Two damaged drip catches were identified. However, the overall condition of these areas was excellen Virtually no leaks existed. The inspectors observert that system engineering and operations personnel also conducted walkdowns in normally inaccessible areas while power was reduced, effectively minimizing dose while actively assessing the ma,erial condition of the plant. The inspectors observed proper radworker practices and effective dose controls, including good RP support of the walkdown . _ . _ . _ . _ _ . . _ . _ . _ . _ . . . ._ . _ _ . . _ _ . - . _ _ _ . _ . . . _ . _ . ~ . _ . _ _

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R3- i Radiological Protootton and Chem.stry Procedures and Documentation i

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R Initiation of Hydrogen Watsi ^?n!1 tty

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as inspection Scope (71750 )

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The inspectors observed oporations and radiation protection (RP) actions upon initiation  :

of hydrogen water chemistry on November 24,1997c The inspectors reviewed

-"  : Procedure 67.000.101, " Performing Surveys and Monitoring Work," and walked down . -

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accessible areas of the plant to verify that the postings were representative of the surveys taken.10bservations were discussed with the RP Manager and RP General Supervisor. ' _;

- Observations and Findinas ,

i The licensee initiated hydrogen water chemistry (HWC) for the first time since the _

. October cutage; Prior to that time, HWC had only been put into service for testing during '

the previous cycle, and for a brief time in July 1997. :The inspectors observed that-

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RP technicians made changing radiological conditions very visible to site personnel due

! to the increased dose rates in various areas of the plant.-

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The inspectors verified that plant radiological postings were correct for having HWC in

service, and new high radiation areas were controlled per station procedures. The E inspectors identified that when RP technicians identified limited changes to existing -

~ surveys, a partiM survey map was made; However, the inspectors noted that this could 1 lead to confusion because existing survey maps did not clearly indicate that additional

"

surveys partially superseded information shown. The inspectors also noted that survey

? maps did not contain a block for recording the exishg HWC flow rate leven though this 1- information was procedurally required to be recorde In response to the inspectors' concems, the licensee reviewoo its practices for making :

. survey information available and indicating the existence of supplemental or superseded

' informatio . Conclusions q

i  : The inspectors concluded that the licensee performed appropriate surveys following

' changes in plant conditions, such as starting up the hydrogen water chemistry system.

i- 1 However, general area survey maps wt,rs not superseded when conditions on a portion .

of the map changedElt was not always clear that additional survey maps needed to be t 4 . reviewed?

R8 ' ' : Miscellaneous Radiation Protection and Chemistry Issues

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R8.1 - (Closed) Violation 50-341/g7003-13: Failure to obtain briefing of radiological work area conditions.;The Nfl0 withdrew this violation in a letter to the licenses dated November 12,1997/ This item is close >

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V. Menanoment Meetinas -

- Xi - Exit Meeting Summary

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The inspectors presentcd the inspection results to members of i:censee m1nagement at the conclusion of the instrection on January 5,1998. The llec 1see acknowledged the findings presented, The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary No proprietary information was identifie ;

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PARTIAL LIST OF PERSONS CONTACTED t- M9tDatt

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S. Booker, Electrical Maintenance Superintendent O. Cobb, Operations Superintendent- >

- W Colonnello, Work Week Manager R.- Delong, Superintendent, System Engineering

- T. Dong, NSGS, Technical Engineering

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P. Fossier, Plant Manager J. Greene, Superintendent of Maintenance Support

K. Howard, Superintendent, Plant Support Engineering E. Kokosky, Superintendent, RP and Chemistry r

- J, Korte, Director, Nuclear Security -

R. Laubenstein, Mechanical Maintenance Superintendent  :

P Lynch, NSS, Operations

- R. Matthews, l&C Maintenance Superinten3nt

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W. Miller. Work Week Manager

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J Moyers, NQA Director N. Peterson, Acting Direcor, Nuclear Licensing

J. Plona, Technical Director

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T Schehr, Operating Engineer HEQ

-- A Kugler, Fermi 2 Project Manager, NRR

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E. Kendrick, Reactor Systems Branch, NRR p - J. Guzman, Reactor Inspecto , Rill

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INSPECTION PROCEDURES USED - q IP37001: _

10 CFR 50.59 Safety Evaluation Program (

' IP 37551: . . Onsite Engineering - _

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IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and

. Preventing Problems-

-IP 61726: Surveillance Observations . .

. , IP 62707: . Maintenance Observation -

" ; IP 71707:-

' Plant Operations ,

IP 71714: Cold Weather Preparations -

IP 71750; . Plant Support Activities

, = IP 86700:. Spent Fuel Pool Activities-

IP.92901: Followup - Operations

,- :IP 92902; : : Followup - Engineering

IP 92903: - Followup - Maintenance t - ITEMS OPENED, CLOSED, AND DISCUSSED E Opened

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50-341/97016-0 NCV Failure to Take Reactor Coolant System Conductivity Measurement

50-341/97016-02 URI Receipt and Disposition of 10 CFR 21 Notices '

t b 50-341/97016-03 URI Inspection and Testing of 480 Volt Breakers

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Closed

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50-341/95008-01 IFl Combustion Turbine Generator 11-1 Deficiencies Not Allin Work

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50-341/96002-09 - VIO e Motor Operated Actuator Separated From Turbine Steam Drain ,

t Valve

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' 50 341/95012-02a VIO ' :l'nadequats Procedures for Testing Safety-Related Batter Chargers '

50-341/97003-05 . VIO Inadequate Procedure to Install Fully Ready Battery Cells

50 341/97010-00 LER- High Pressure Coolant Injection Auxiliary Oil Pump Failed to Run

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on Turbine Coast Down n

50-341/96004-08 .IFl ' Multiple Reactor Watar Sample System Flow Glass Failures 50-341/96003-03 IFl Control Center Heating, Ventilation, and Air Conditioning System

Design Criteria -

'50 341/97003-13 VIO Failure to obtain Briefing of Radiological Work Area Conditions 50 341/97016-01- NCV Failure to Take Reactor Coolant System Conductivity Measurement

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_ Discussed

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50-341/95012-0 IFl' Combustion Turbine Generator 11-1 Reliability Problem ,

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LIST OF ACRONYMS USED i ABB- Asea Brown Boveria CAR Condition Assessment Resolution Documents CTG Combustion Turbine Germrator DER Deviation Event Report HWC Hydrogen Water Chemistry IFl Inspection Followup item IPTE Infrequently Performed Test / Evolution -

'LER Licensee Event Report MOV-- Motor Operated Valves NCV Non-Cited Violation psi Pounds per Square Inch RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal NSS . Nuclear Shift Supervisor RP - Radiation Protection SOE Sequence of Events test -

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Technical Specifications UFSAR Updated Final Safety Analysis Report 4 URI Unresolved item VIO . Violation

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