IR 05000341/1999002
| ML20207J157 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207J144 | List: |
| References | |
| 50-341-99-02, 50-341-99-2, NUDOCS 9903160202 | |
| Download: ML20207J157 (32) | |
Text
_ _ _ _ _ __ . _ _ . . _ _ _ _ . . _ _. .
0 l
U.S. NUCLEAR REGULATORY COMMISSION REGIONlli i
i
'
Docket No: 50-341 License No: NPF-43 :
1 Repod No: 50-341/99002 (DRS)
Facility: Fermi Nuclear Generating Station e
Licensee: The Detroit Edison Company Location 6400 North Dixie Highway Newport, MI 48166 Inspection Report: 341/99002 (DRS)
Inspection Performed: January 11 - 29,1999
Inspectors: H. A. Walker, Team Leader ;
C. H. Brown, Reactor Engineer I. N. Jackiw, Reactor Engineer l V. P. Lougheed, Reactor Engineer i
'
R. Mendez, Reactor Engineer R. A. Winter, Reactor Engineer i R. A. Westberg, Reactor Engineer j C. J. Baron, Contract inspector !
i Approved by: J. M. Jacobson, Chief i Mechanical Engineering Branch j Division of Reactor Safety l
l l
9903160202 990308 PDR ADOCK 05000341 g PM
_
. - ., _ _ _ _ _ _ . _ _ _ _ . _ . . _ _ _ . . _ _ . _ . . . . .. _ _ _ . _- _
. ,
q
i
!
EXECUTIVE SUMMARY
!
Fermi Nuclear Generating Station !
NRC Inspection Report 50-341/99002 (DRS) !
- This 'was an announced team inspection of approximately three weeks duration to review engineering and technical support and corrective actions. The inspection included a review of i
- 50.59 evaluations and screenings as well as a review of selected NRC issues from previous !
inspections. The following statements summarize the inspection results:
. - The methods used to control design changes and modifications at the Fermi plant were -
effective. Modification packages were complete, well prepared, and of good technical !
quality. Plant changes were adequately designed and installed and effective post
.
!
modification testing was specified and performed. The respective system and design i engineers were qualified, experienced, and knowledgeable of the modifications in their assigned systems. Design configuration and configuration controls were maintained ;
throughout the proces !
i
. The 10 CFR 50.59 evaluation and screening program was effective. The program !
'
ensured that trained and qualified personnel performed the necessary reviews and j evaluations. Evaluations were performed for plant changes when required and the ;
'
evaluations were generally thorough with 10 CFR 50.59 questions appropriately answere l
. With one noted exception, temporary modifications were well controlled, were of good j technical quality and were properly implemented. Engineering personnel were J adequately involved and were responsive to plant issues in this are {
. A desi0n control weakness existed in design calculations. Three of six older j calcu:ations, recently revised for plant modifications, contained errors, which were not i detected when the calculations were revised. While the errors did not result in 1
- inoperable equipment, a substantial reduction in safety margins resulted. A violation was j written on the three calculation error l
. The corrective action program was strong, effective and well implemented. Throughout i all levels of the plant organizations, there was a widespread acceptance of the condition I assessment resolution document (CARD) system and an understanding when a CARD should be initiated. In almost all cases, corrective actions were appropriate and cause investigation and actions to prevent recurrence were performed when require ]
. Trending of CARD information, both in regard to quality probler3s and CARD statistics, was very good. The " CARD wall" was a positive initiative, which was used to provide a unique visual method for immediate trending feedback during a plant outage. The licensee had identified and was taking steps to combat the growing backlog of open CARDS, which was the only negative statistic in the CARD progra i
-
+_s -
- _- . _ . m -+'i -t-'-7 r y i'<n----
- _ ~ . _ _ -_ - . . - _ - . =-. . - -. - - - . . .- -
.
!
. Technical Specification (TS) surveillance requirements were properly identified in the procedures reviewed and were effectively implemented. Pressure gauge inaccursc%
and the application of instrument uncertainty to surveillance test proceduG was not always adequately addressed. Although these minor discrepancie.t were noted, the overall surveillance results were good and were within the required acceptance criteri . Engineering support for maintenance was good. Excellent support we provided in predictive maintenance by the use of thermography to identify electrical voblems. A t minor problem was identified in this area with the lack of documentation ni encineering walk-down results. Responsible licensee personnel appeared to be well qualified, experienced and cognizant of work activities and issue !
- The Operating Experience Program was acceptable and adequately responded to NRC and industry information. In most cases, the information received was appropriately reviewed, evaluated and the necessary actions were taken. The inspectors identified one example where the documented response did not properly address an information notic . Nuclear Quality Assurance (NOA) audits and surveillances were adequately performe :
The activities were performed by well trained and experienced engineers and were of i good quality. The reviews were in-depth and findings were written when appropriat I Actions taken to address identified issues were normally adequate and timely and follow-up was provided as neede . The three independent plant review organizations performed well and were effective in complethg assigned reviews, investigations and evaluations. Support and assistance to I plant management by these organizations in the resolution of problems was very goo ;
Members of the groups were experienced and were aggressive in pursuing plant problems and issue l
l
._ _ _ . _ . _ _ . _ . _ _ . _ . - . -- ._._m...- . _ . _ _ _ .
_,
'=
l
.. ;
I
.
!
Report Details l
-
i lil. Engineering
The review of engineering included both design and support engineering activities. The design !'
review included design changes, temporary modifications and 10 CFR 50.59 evaluations and screenings. Engineering support included systems engineering, problem resolution and corrective action activities as well as normal engineering involvement with operations, maintenance and other plant organization ;
..
l E1 Conduct of Engineering !
!
E Desion Chanoes and Modificationc j i . Insoection Scooe (37550,37700) ;
'
- -
' The methods used to control design changes and modifications were reviewed to verify j adequacy, control, and compliance with regulatory requirements. The review included . !
the tLasic design change procedures and 30 selected modification packages. The l modification packages selected included both installed and non-installed modifications !
with emphasis on installed modifications. - Modification packages were reviewed in detail, !
. discussed with cognizant system and design engineers and the inspectors walked down j accessible portions of some modification installations. Elements of this review included !
10 CFR 50.59 evaluations, screenings and design calculations, which are discussed in !
other sections of this repor j Observations and Findinos During the review of the design change packages, the inspectors noted a few minor administrative errors which were promptly corrected by licensee personnel. Overall the packages reviewed were complete, of good quality and were adequate to accomplish i the design changes. Installed modifications were properly installed and teste . Post-modification testing for the modifications were effective in verifying that the modiffed equipment would perform its designed function. Affected drawings were verified to be revised or red-lined as appropriate and, when necessary, operating procedures were revised or written. The overall material condition of the plant, -
observed during walkdowns, was goo During the review of Modification EDP- 29024, "ECCS Suction Strainer Replacement,"
Revision 0, the inspector identifiexi several concems associated with the ECCS calculations which were affected by the modification. The specific calculation concems are discussed in Section E1.4 of this repor j Conclusions -
Based on the inspection results, the inspectors concluded that the methods used to control design changes and modifications at the Fermi plant were effective. Modification
4 l
-- - - . - - -- . - - - - . ,. . .- -, -. ,
-. _ ,
'
i
!
.
packages were complete and of good technical quality. Plant changes were adequately designed and installed and effective post modification testing was specified and performed. Design configuration and configuration controls were maintained throughout l the proces E1.2 10 CFR 50.59 Evaluations and Screeninas Inspection Scoce (37001)
The methods used and procedure used to control 10 CFR 50.59 screenings and evaluations were reviewed to verify adequacy, control, and compliance with regulatory requirements. Emphasis in this review was on design changes and modification CFR 50.59 evaluations and screenings were discussed with cognizant licensee personnel and selected evaluations were reviewed in detail to verify implementation and compliance with the requirements of 10 CFR 50.5 Observations and Findinas The 10 CFR 50.59 screenings and evaluations reviewed were appropriately prepared, of good quality and were consistent with licensee procedures and regulatory requirement l Implementing procedures appropriately described effective methods for controlling and i performing 10 CFR 50.59 screenings and evaluations. Licensee personnel reviewed appropriate documents during the screenings and evaluations. The list of the reviewed documents, the description of the changes, and the responses to the 10 CFR 50.59 questions were found to be detailed, complete, and consistent with the associated modification packages, licensing change requests, and design calculations. The evaluations adequately addressed the effects of the proposed changes on plant operations, interactions with other systems and components, any new failure modes, the effects on accidents and transients, and whether an unreviewed safety question existe The conclusions that these design changes did not result in unreviewed safety questions were appropriat In response to previously identified problems with the thoroughness and censistency of 10 CFR 50.59 screenings and evaluations, licensee personnel had developed and conducted a comprehensive week long training course to train personnel performing these screenings and evaluations. The training materials used were consistent with the procedure and NRC requirements. The training program was an excellent method for ensuring that trained and qualified personnel prepared and reviewed 10 CFR 50.59 screenings and evaluation Conclusicas The inspectors concluded that the 10 CFR 50.59 evaluation and screening program was effective. The program ensured that trained and qualified personnel performed the necessary reviews and evaluations. Evaluations were performed for plant changes j when required and the evaluations were generally thorough with 10 CFR 50.59 questions appropriately answered.
l
!
'
p ;
-
.
- D I
E1.3. Temoorary Modifications Insoection Scope (37550,37700)
.
l l
The methods used to control temporary modifications were reviewed to verify adequacy, control, and compliance with regulatory requirements. The review included the j controlling procedure and selected open temporary modification packages, which also j included the appropriate 10 CFR 50.59 evaluations or screenings. Temporary
. :
modifications were discussed with cognizant licensee personnel and, in some cases, the !
inspectors walked down accessible portions of installed temporary modification Observations and Findinos l
The temporary modification process provided adequate controls for temporarily installed j material and equipment. Temporary modifications were required to be reviewed by a I cognizant engineer, usually the system engineer, and a 10 CFR 50.59 screening or 3 evaluation was required to be completed prior to installatio There were few open temporary modifications and very few had been open for longer than one operating cycle. The oldest open temporary modification had been installed for approximately 30 months. The Off Site Review Organization (OSRO) comments j contributed to the technical quality of temporary modifications and OSRO approval was !
- required to extend the scheduled removal date. The inspectors noted that removal of two of the oldest temporary modifications was scheduled for February 1999. During i discussions, licensee personnel were knowledgeable of the modifications and the backgroun During a plant walk-down, the inspectors noted a portable high efficiency particle absorber filter and pump unit attached to each re-circulation pump motor generator (MG)
set. - The installation of this filter unit was not a permanent modification and was not listed as a temporary modification. During discussions on this issue, licensee personnel stated that the units were originally installed in 1992 as a temporary modification, but were no longer controlled under the temporary modification program. The inspectors noted that minimal plant controls, such as, " Restraint of Loose items in the Plant" and the temporary electrical power procedures were used for the installation. Licensee personnel had independently identified the problem and, after some indecisiveness, in December 1998
' issued an EDP rather than a temporary modification in order to bring this item under proper administrative control. Although of low safety significance, this was an undocumented temporary modificatio Conclusions Based on the inspection results, the inspectors concluded that, with one noted exception, temporary modifications were well controlled. Temporary modifications were bf good technical quality and were properly implemented. Engineering personnel were adequately involved and were responsive to plant issues in this are ;
!
!
!
l i
- , = - - .
. - .-
. . . _ . . _ . _ _ . . . . . . _ . . . _ _ _ _ _ . _ _
_ _ . _ . _ _ . _ . - _ _ . ,
~
> l
,.
l
.
. E1.4 Calculations . .
i Insoection Scope (37550,37700) :
!
~ The methods used in performing and revising design calculations for modifications and l design changes were reviewed to verify adequacy, control, and compliance with j regulatory requirements. The review included the controlling procedure and six selected i design calculations, which supported recent modification packages. The calculations !
were reviewed for accuracy and to verify appropriate inputs, assumptions, and l calculation methods. The calculations were discussed with cognizant licensee l personne }
! Observations and Findinos !
Changes to existing calculations, required by modifications, were not always f accomplished such that the changes could be easily understood. in some cases,
'
updates were found to be confusing, especially for the older and more complex : i I
~ calculations. Only the calculation pages affected by the respective modification were marked up and included in the modification package. Some items were lined out and .
hand written changes were entered. Licensee personnel stated that changes were i normally incorporated into calculations when there were five or more changes posted l against a calculation. In addition, it appeared that only the portions of the calculations j directly affected by the modification were given a detailed review during the modification j process. This limited review resulted in a missed opportunity to verify that the design i calculations being used to support design modifications were correct and curren l J
The inspectors identified three conditions where design calculations for safety related j systems contained errors or failed to address the appropriate TS requirement l l
. Calculation DC-0367 " Design Calculations for R.H.R. System," Revision L, l dated February 13,1996, evaluated the addition of a new LPCl/R.H.R. cross-tie header block valve on the analyzed hydraulic cor.ditions of the LPCl/R. system under post-accident conditions. Based on the manufacturer's pump curve, the available LPCl/R.H.R. pump head was 470 feet at 13,000 gallons per minute (g.p.m.) per pump (Item A-2, Page 2). The revised calculation incorrectly concluded that the addition of the va!ve would result in a LPCl/R.H.R. pump head requirement of approximately 402 feet, an acceptable value. The revision addressed the friction losses in the piping system, but failed to account for the effects of the reactor vessel pressure (approximately 47 feet) and the system elevation differences (approximately 70 feet), even though these effects were addressed in previous revisions. The incorporation of these values appeared to -
place the required pump head above that which was availabl The analyzed mode of LPCl/R.H.R. post-accident operation was based on LPCI Accident - Mode B of the GE Process Diagram, included in Revision 8 of the updated final safety analysis report (USAR) as Figure 6.3-14. USAR Figure 6.3-14 presented a LPC1/R.H.R. flow of 12,930 g.p.m. per pump (versus )
7 l
l
l
- ._ _ - _ . . - _ ___ ._ 1~ . ._ . - - _. - _ l
_ . . . _ . _ _ _ _ . _ . _
.,
., ;
13,000 g.p.m. In the calculation) for this mode. However, USAR Table 6.3-6, ,
stated that the ECCS analysis used a flow of only 22,050 g.p.m. for two l LPCl/R.H.R. pumps, corresponding to a flow of 11,025 per pump. Based on the l margin available between the LPCl/R.H.R. design flow values and the flow values
.
j used in the ECCS analysis, it appeared that the calculation error would not adversely affect the capability of the LPCl/R.H.R. system to perform its required safety function. Licensee personnelindependently agreed and stated that calculation DC-0367 would be correcte ' The failure to include all appropriate values when computing the required pump head is considered an example of a design control violation of Criterion ill of 10 CFR 50, Appendix B (VIO 341/99002-01 A)(DRS).
. Calculation DC-0230 " Core Spray System," Revision F addressed the test, post-accident, and run-out flow conditions of the CS system. This calculation sized a flow restriction orifice to prevent the specified maximum system flow of 3950 g.p.m. per pump from being exceeded during run-out conditions. The post-accident CS system flows were calculated based on this orifice being installed in the system. However, the orifice data included in calculation DC-0230 was not correct as the orifice had been replaced with a different sized orifice during pre-operational testing. The correct orifice data was included in another calculation, DC-0204, " Sizing Restricting Orifice Diameters and Thickness,"
Revision E. The licensee initiated CARD 99-10431, dated January 27,1999, during the inspection to evaluate this condition. The evaluation associated with this CARD determined that, for the post accident CS flow calculations, the error due to using the incorrect orifice data was less than the margin included in the analysis, and that the CS system remained operabl TS surveillance requirements 4.5.1.b.1 required that two core spray pumps develop a flow of at least 6350 g.p.m. against a test line pressure of greater than or equal to 270 psig, corresponding to a reactor vessel pressure of greater than or equal to 100 psig. This test pressure acceptance criterion was documented in calculation DC-5079, *RHR and CS Tech Spec Surveillance Pump Discharge Pressures," Revision 0, which used the pressure drop data from calculation DC-0230. The error in calculation DC-0230 adversely affected calculatio DC-5079, reducing the cabulated test pressure to within 0.1 psi of the TS valu The new flows were still above the TS requirement so the pumps remained operable. Licensee personnel agreed and stated that calculations DC-0230 and DC-5079 would be correcte The failure to ensure the accuracy of design inputs to calculations DC-0230 and i DC-5079 is considered a second example of a violation of Criteria Ill 10 CFR 50, j Appendix B (VIO 341/99002-01B)(DRS). !
l I
= Calculation DC-0465 - "ECCS Suction Line Air Ingestion," Revision B, determined the submergence at which air could potentially be entrained in the ECCS suction lines from the suppression pool. Modification EDP-29024 replaced
i i . - - . .. - . , -
,
m
the ECCS suction strainers with larger strainers and affected calculation DC-0885. The calculation and the modification were based on the minimum suppression pool water elevation during plant operational conditions 1,2, and Neither the calculation or the modification addressed the minimum suppression .
pool water level allowed during operational conditions 4 and 5. TS 3.5. allowed the minimum suppression chamber water level to be reduced during )
mode 4 and 5 operations. At a suppression pool level of nine feet, the ECCS suction strainers would be partially uncovered. TS Basis 3/4.5.3 states,"The minimum water volume is based on the net positive suction head, re-circulation volume and vortex prevention plus a 2.4' safety margin for conservatism."
Section 3.5.2 of the TS required the CS and LPCI systems to be partially operable and capable of taking suction from the suppression pool during mode 4 and 5 operations. During the inspection the licensee reviewed calculation DC-0885 and determined that the system would be capable of operation during '
modes 4 and 5 with a reduced minimum suppression chamber water leve Licensee personnel stated calculation DC-0885 would be correcte The failure to consider all applicable modes of operation during the revision of i calculation DC-0885 and development of modification EDP-29024 is considered i to be a third example of a violation of Criteria Ill of 10 CFR 50, Appendix B (VIO 341/99002-01C)(DRS). ;
I Conclusions The inspectors concluded that a design control weakness existed. Three of six older l design calculations, recently revised for plant modifications, contained errors, which were l not detected when the calculations were revised. While the errors did not result in )
inoperable equipment, a substantial reduction in safety margins resulted. A violation was written on the three calculation error E2 Engineering Support of Facilities and Equipment The inspectors reviewed the effectiveness of engineering support to plant organizations, which included plant management, operations and maintenance. Much of the engineering support involved assistance in the documentation, evaluation and resolution of problem !
E Corrective Action Proaram Inspection Scope (40500)
The methods used to control the corrective action process were reviewed to verify adequacy and effectiveness in identifying and correcting problems. This review included controlling procedures, records and reports. Timeliness and priority of actions completed or scheduled were considered as well as tracking of actions to correct or minimize problems. This included reviews of selected CARDS and associated ,
effectiveness reviews as well as discussions of corrective issues with cognizant licensee !
personnel, which included station personnel in the operations, maintenance, and ;
l
_ . _ _ .
. _ _ _ _ .__ _ __ _
'
,
C engineering departments. The CARDS reviewed are listed in the section entitled,
" Licensee Documents and Records Reviewed During the incpection" located near the end of this repor b. Observations and Findinas The inspectors determined that CARDS were normally initiated for problems that ,
'
occurred onsite. The initiation level was extremely low, and even minor problems were captured by a CARD. During discussions with licensee personnel, the inspectors noted that both management and non-management personnel agreed that one of their first actions, on finding a problem, would be to write a CARD. The CARD system was l perceived as a way to get problems fixed and licensee personnel indicated a wiliness to !
write CARDS. Much of the success of the program was due to positive management support of the program, a successful feedback mechanism, and positive results from the use of CARD Another factor leading to the success of the CARD program was the use of the CARD oversight panel and CARD review board. These reviews ensured that CARDS were assigned the proper priority and assigned to the correct organization. The inspectors ;
attended an oversight panel meeting and found the meeting to be well organized. The CARDS were reviewed quickly and agreement was reached as to which organization 1 would take ownership. Two CARDS were brought back to the ownership panel to be l reassigned to other groups. The CARD system differentiated between determining why l a problem occurred (the assigned level) and fixing the problem (the assigned priority). l This ensured timely correction of problems without requiring detailed root cause analysis of insignificant issues. The inspectors noted that the CARD oversight panel tended to be conservative when assigning the CARD priority (level). The inspectors reviewed l approximately 50 CARDS for proper level assignment and agreed that the appropriate l CARD level was assigne l
!
Through review of approximately 30 CARDS with completed corrective actions, the i inspectors found that, in almost all cases, the corrective actions appeared appropriate to resolve the identified problem and to prevent recurrence. For example, CARD 98-22099 !
'
noted that three switches were left with reset values outside the (non-TS) specified acceptance criteria. The corrective actions were to evaluate the acceptability of the ;
as-; eft values and to retrain the technicians regarding the acceptance criteria (confusion l'
existed due to some values being "less than or equal to" and others being " greater than"). CARDS 98-17187 and 98-18389 provided good follow through on an issue where the safety relief valve (SRV) bodies weren't being tracked properly. Level 1 CARDS had formal root cause analyses done. The inspectors reviewed several completed Level 1 CARDS and found them to be reasonably thorough and complete. For example, CARDS 97-11316,98-12413 and 98-18735 provided a thorough root cause evaluation for the repetitive SRV failures to lift, in a few cases the actions taken did not appear to be appropriate or required further ,
discussion. Discussions on these CARDS follow: 1
w
'^
t
.
-
-. . !
,
i
.
CARD 98-01994 identified a maintenance rule functional failure of an emergency lighting unit (ELU).- Disposition of the CARD was acceptable; however, the CARD stated that the number of failures did not exceed the 130 failures per year aliowed by the maintenance rule performance criteria. The inspector questioned l this performance criteria since only 210 ELUs were tested at the plant. The ;
inspectors leamed that the ELU performance criteria included the monthly !
surveillances as well as the two year battery discharge failures without any !
differentiation. Licensee personnel did not appear to consider that the function ,
of the ELUs was to operate for eight hours. A one hundred percent failure of
.
105 ELUs, tested yearly for the battery discharge test, would be less than the 1
'
allowed 130 failures. On February 5,1999, the !!ccnsee personnel notified the inspectors that the performance criteria would be modified to separate the monthly test and the 8-hour Appendix R test. This item is unresolved pending ,
further review to determine if the actual number of battery discharge failures !
exceeded requirements (URI 341/99002-02) (DRS). j l
. CARD 98-11990 identified four non-safety-related emergency diesel generator i discharge temperature control switches that were found out of tolerance 26 out of j 28 times over the past 14 years. In addition, the inspectors noted that two of the j four switches were never found to be in tolerance during the 14 year period. All
-]
the switches had been calibrated on a two to three year frequency and licensee personnel proposed to reduce the calibration frequency of these switches. The inspectors noted that two of the switches, calibrated on a nine month calibration interval, were still found out-of-tolerance when they were last calibrated. The inspectors noted that licensee personnel had not reviewed the switches for proper application to determine if a different switch should be used. ' This matter
. was discussed with licensee personnel, who stated that the CARD would remain open and investigation of the problem would continu '
. CARDS 98-4693 and 98-18726 pertained to a minor water hammer in the high pressure coolant injection (HPCI) system. During a HPCI pump surveillance in i July,1998, a minor water hammer occurred in the system; however, no damage resulted. A large water hammer had occurred in the HPCI piping in 1993, resulting in damage to several discharge pipe hangers. Conditions were reviewed to determine if inadequate corrective action to the 1993 water hammer might have caused or contributed to the 1998 event. Licensee personnel were unable to determine a specific cause of the 1998 water hammer event and could not explain why water hammer had not occurred during pump surveillance testing the three previous years. However, the event could not be traced to inadequate action taken to correct the 1993 event.
. - An additional positive feature of the CARD program was the performance of effectiveness reviews for Level 1 and escalated CARDS, as well as selected Level 2' The inspectors reviewed the completed effectiveness reviews, and found them to
- generally be of sufficient depth to confirm the effectiveness of the corrective actions.
p t 11 i
-- - g g -<---m-n-, m., . , ,y.,e e- ,.,r y m -.,*r- - --
-- .- . .. .. . _ . . . - - - . - - .. - .. --
'
,
4 Conclusions Based on the inspection results, the inspectors concluded that the corrective action program was strong, effective and wellimplemented. Throughout alllevels of the organizations there was a widespread acceptance of the CARD system and an understanding when a CARD should be initiated. In almost all cases, corrective actions were appropriate and cause investigation and actions to prevent recurrence were performed when require E2.2 Trendina Inspection Scope (40500)
The methods used to determine repetitive failures and detect negative quality trends were reviewed to verify adequacy, control, and compliance with regulatory requirement The review included the controlling procedures, records, trend reports, and actions taken when negative trends were noted. The trending program and activities were discussed with cognizant licensee personnel, Observations and Findinas The basic document used to identify problems and for trending was the CARD. When CARDS were initiated, the preparer or his supervisor were asked to identify an initial cause code. This encompassed such areas as deficient procedures, equipment malfunctions, human errors, etc. These items would be trended to determine if problems were increasing in these areas and a cause for the increase could be determined. For Level 1,2, and 3 CARDS, a final causo code was also assigned, which could be compared to the initial cause, or trended separatel During the recent sixth refueling outage, the NQA organization had a " CARD wall" which was used for immediate trending. On a large, blank wall the CARD administrator !
arranged note cards with CARD numbers on them under types of events such as .
'
" Design problems"" Leaks" and "RP Practice." These notes were then color coded by major work activities and other areas to track the cause of the events. As trends started developing, NQA would issue a short memo alerting people to developing trends and reminding them of correct practices. This provided immediate feedback on developing trends so that corrective actions could be taken during the ongoing refueling outage, as compared to a more traditional" analyze the outage after it's over to decide how to fix the next one." In addition plant management was provided a more detailed overlook on the outage progression. For example, partway through the outage, NQA personnel recognized that the equipment problems (which were dominating the board as a major outage problem) were overwhelmingly due to balance-of-plant (BOP) equipment. They were then able to characterize for management how the lack of preventive maintenance (PM) on BOP equipment was impacting the outage. This type of immediate feedback appeared to be a positive initiative to aid in controlling outage problem .
. .
, ,
,.
!
In addition, licensee personnel tracked statistical information about the CARD process as well as diagnostic information about identified problems. The information included )
tracking the overall number and age of open CARDS by responsible departments. The ;
number of open CARDS had gradually increased since the program had been initiated; l however, this trend had somewhat abated in late December 1998 and early i
'
January 1999 with the nun.ber of open CARDS slightly decreasing. . The inspectors noted that the plant support engineering department had the largest backlog of open {
CARDS, which had increased rapidly in _the recent past. The plant support engineering I director was aware of the growing backlog and had taken some actions to reduce the I increasing tren ! Conclusions Based on the inspection results, the inspectors concluded that trending of CARD information for both quality problems and CARD statistics was very good. The " CARD wall" was a positive initiative, which was used to provide a unique visual method for
)
immediate trending feedback during a plant outage. The licensee had identified and was taking steps to combat the growing backlog of open CARDS, which was the only negative statistic in the CARD program, noted by the inspector E2.3 Enaineerina Sucoort to Surveillance Testina l Inspection Scooe (37550) l i
Thirty-eight completed electrical and mechanical surveillance test procedures and records were reviewed for adequacy of content, proper implementation and to verify that the applicable TS surveillance requirements were met. Selected surveillance records were discussed with cognizant licensee personnel and, in some cases, the inspectors walked down portions of the respective equipment, Observations and Findinas Most of the surveillance test procedures and records reviewed were of good quality, were properly implemented, were adequate and properly performed. Engineering involvement and support was evident in the development of procedures, implementation
,
of surveillance tests and the resolts:>n of problems. Minor problems or concerns were
'
noted with a few of the test records reviewe . . Surveillance Test Procedures 24.203.02 and 24.204.01 -These two surveillance test procedures," Division 1 CSS Pump and Valve Operability, and Automatic Actuation" and " Division 1 LPCI and Suppression Pool Cooling / Spray Pump and Valve Operability Test" had a common problem. Both required flow and pressure measurements to verify that TS surveillance requirements were met. Allowances for instrument uncertainties were not included in these surveillance procedures or in applicable calculations. During discussions with licensee personnel, the inspectors were told that instrument inaccuracies and set point calculations had not been performed for instruments that did not perform an automatic or i
13 l i
!
)
. _ . . . _ _ _ . - . . . , - - - - _ . . . _ _ . . - . - - - _- , ..- . . - , . _, ,._- - --
.-. - - - -.- - __ _ --- -.- - . . - --. ... - --_ -
+
,.
r protective function. However, the flow and pressures recorded during actual testing were well above the minimum values required by TS. Therefore, these instrument uncertainties would not adversely affect the capability of the systems ,
to perform their required functions. Licensee personnel stated that the inclusion
'of allowances for instrument uncertainty in surveillance test procedures would be investigate . Surveillance Test Procedure 35.306 008-The surveillance test procedure for motor control centers, " Motor Control Center Load Compartment," required that the pickup voltage for safety related contactors be less than 85.2 Volts. The ;
voltage requirement was obtained from a system voltage study that used vendor
- minimum pickup voltage data for size 2 motor starters. The inspectors noted that l the pick-up voltage for some contactors was as much as 91.4 Volts, which -
exceeded the acceptance criteria of 85.2 Volts. Licensee personnel determined l the minimum bus voltage at the safety-related bus to be greater than the pick up
. voltage of the contactor coils and no further action was considered necessar '
. Surveillance Test Procedure 42.309.005 -The battery surveillance test procedure " Division % 130/260 VDC Battery Capacity Test," Revision 24. allowed ,
battery testing to be stopped to prevent a cell from reaching reverse polarit '
This occurred as much as three times during the performance of some of the capacity discharge tests. The Institute of Electrical and electronic Engineers ;
(IEEE) guide for battery testing stated that no more than one downtime period should be allowed when a battery is being tested. This guidance was included so ,
that the capacity of the battery could be calculated more accurately. The !
inspector verified that the downtime periods did not adversely affect the overall i capacity calculations and no examples were identified where the capacity was i less than 100 percent. Licensee personnel stated that the surveillance procedure would be changed to comply with the IEEE standar ! Conclusions Based on the inspection results, the inspectors concluded that engineering support for TS surveillances was good and the overall program was effective. TS requirements were properly identified in the procedures and were effectively implemented. Even though some minor concems were noted, the overall surveillance results were acceptable and were within the required acceptance criteri E2.4 Enoineerino Suooort to Maintenance Inspection Scope (37550)
The methods used by engineering to provide support to maintenance were reviewed to verify adequacy and control. Emphasis in this review was on the involvement of engineering in the development and implementation of predictive and preventive maintenance. The review included relevant procedures and records as well as ;
discussions of the issues with cognizant licensee personne ;
! . . .-. . .
. - _ . _ _ . . _ _ _ _ _ _ _ . _ _ _ . _ . _ . _ _ _
[ , , '
, .
L Observations and Findinas The implementing procedures adequately described the duties and responsibilities of the i system engineers and the engineering support staff in supporting maintenance and other 7
'
organizations. Responsibilities for PM, predictive maintenance, modifications and
'
involvement in the resolution of problems were discussed with licensee personne The inspectors interviewed selected system engineers and noted that CARD system adequately involved system engineers in problem Investigation and resolution. Both
,
system and design engineers were found to be qualified and experienced in their !
respective positions and were involved in prioritizing and assisting in appropriate maintenance activities. System engineers directly interfaced with maintenance :
personnel and frequently witnessed some PM activities. The inspectors noted that .
,
system engineers trended equipment and component failures, evaluated and
'
incorporated applicable vendor information and were involved with user groups. In j
'
addition, the inspectors noted that the maintenance departments and the engineering staff placed a significant effort in overhauling all the safety-related 4kV and 480V breakers and establishing a PM schedule in accordance with vendor recommendations, i
The inspectors noted one minor concem. The " System Engineering and Maintenance Engineering Roles and Responsibilities" stated the system engineer was expected to complete a visual walkdown of the assigned systems at least bi-weekly. The manual stated that the walkdowns included an assessment of the material condition, including j
. visual observations. The inspectors were informed that the results of the walkdowns-were documented on checkiists that the system engineers carried in to the field and that CARDS were written to document discrepant conditions when noted. The inspectors noted that, in general, the results of the walkdowns were not documented or kept for trending purpose As a part of plant predictive maintenance, engineering had established and was conducting periodic thermography scanning of electrical panels and equipment to identify undetected problems. During the inspection, a " hot spot" was identified at a fuse and fuse clip in MPU #3 Cabinet #2, which supplied power to many non-safety related control
'
room ennunicators and indicators. After review of the problem. engineering proposed that a temporary modification be installed to parallel the hot fuse circuit so the control room indicators could be maintained to allow continued plant operation. The inspectors discussed the planning for the repair with licensee personnel and physically observed the problem panel. Licensee personnel successfully installed the temporary 1 modification, repaired the fuse clip and removed the temporary modification without
- incident. The inspectors considered this well planned and conservative corrective actio Conclusions Based on the inspection .results, the inspectors concluded that engineering support for maintenance was good. Excellent engineering support was provided in predictive maintenance by the use of thermography to identify an electrical problem, which was then combined with careful and conservative planning to make the necessary repairs. A
, , .
,
minor problem was identified with the lack of documentation of engineering walkdown result E2.5 Operatina Exoerience Proaram Inspection Scope (37550,40500)
The methods to use and control outside or industry information and problem prMcations such as generic letters, information notices, Institute of Nuclear Power Operatiora (INPO) notifications, service infom1ation letters, etc., were reviewed to verify adequate I review and action. The review included the controlling procedure and the actions taken I
on selected notification documents. The Operating Experience Program was discussed with cognizant licensee personnel.
l Observations and Findinas The inspectors reviewed procedure MLS04," Operating Experience Program,"
Revision 6. The procedure defined the operating experience program responsibilities for the receipt, dissemination, screening, investigation, evaluation, appropriate disposition, scope and documentation of incoming guidance for conducting program effectiveness reviews and preparing outing Nuclear Network messages. The program was used to assess information on generic type problems originating from both inside and outside the licensee's organization. The innpectors noted that the licensee had adequately responded and taken corrective actions to address outside or industry informatio Conclusions Based on the inspection results, the inspectors concluded that the Operating Experience Program was acceptable and was adequately involved in responding to and correcting industry operating events. In most cases, the information received was appropriately reviewed, evaluated and the necessary actions taken. The inspectors identified one example where the documented response did not properly address an information notic E7 Quality Assurance in Engineering Activities Quality assurance of engineering activities was provided by the NQA organization, who performed surveillances, assessments and required audits of plant activities. In addition, several committees provided an independent review of selected documents, problems, and issues. These activities provided substantial support to corrective action and problem correction and avoidance type activitie .
_ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
7_
g 4
.
E Audits and Surveillances Inspection Scope (40500)
The methods used to perform and control NQA audits and surveillances were reviewed to verify adequacy, control, and compliance with regulatory requirements. The review included the controlling procedures and selected 1997 and 1998 audit and surveillance records as well as discussions with cognizant licensee personne Observations and Findinos Audits were routinely planned and scheduled and were usually broad in scope covering a selected area or function. Surveillances were usually less formal, narrow in scope, more specific and of a much shorter duration. Surveillances normally required limited planning and could be requested by various plant organizations. Licensee personnel performing audits and surveillances were well qualified, experienced and cognizant of audit or surveillance area Audits and surveillance records were of good quality and the findings were of sufficient detail to provide adequate information for necessary corrective actions. Findings were identified and recommended corrective actions, actions completed and NQA follow-up on identified issues were adequately documented. Findings were usually documented on CARDS and the CARD system provided the necessary status, schedule and tracking information. CARDS written by NQA required sign-off by NQA management prior to closur Conclusions ,
Based on the inspection results, the inspectors concluded that NQA audits and surveillances were adequately performed. The audits and surveillances were performed by well trained and experienced engineers and were of good quality. Reviews were in-depth anri findings were written when appropriate. Actions taken to address identified issues were adequate and timely. Follow-up was provided as neede E7.2 Review Committee Activities I Inspection Scope (40500) l The methods used by the three separate and independent review groups at Fermi were ;
'
reviewed by the inspectors to verify adequacy, control, and compliance with regulatory requirements. The review included the controlling procedures and selected records of activities. The three groups were the On-Site Review Organization (OSRO), the Nuclear Safety Review Group (NSRG) and the Independent Safety Engineering Group (ISEG).
The functions, findings and activities of the three groups were discussed with cognizant licensee personne . . .
. . _ _ _ _ _ _ _ _ _ _ _ . _ _ _
.-
_
..
. Observations and Findinas The purpose of the OSRO, NSRG and ISEG groups was to provide technical expertise for continuing systematic assessment of plant documents and activities, which were independent of plant management. The functions included examination of significant plant problems, operating characteristics, NRC issuances, industry advisories, and other sources of plant design and operating experience that might indicate areas for improving plant safety. Ir. dependent reviews and assessments of selected plant activities included maintenance, modifications, operational problems and analysis, and aids in the establishment of programmatic requirements for plant activitie The methods, used by the OSRO, NSRG and ISEG groups, were appropriately described in implementing procedures. The inspectors reviewed selected samples of meeting minutes and activity records and reports, which provided evidence that the described functions were properly implemented. The groups consisted of dedicated full-time experienced engineers and management with experience in variet, discipline '
After completion of reviews, the groups provided required approvals or made detailed recommendations to plant management for plant improvements with emphasis on plant safet The inspectors attended OSLO Meeting #812, held on January 26,1999, and observed that this meeting was conducted in accordance with procedural requirements and in a professional manner. OSLO members raised questions and exchanged ideas about issues that were discussed, Conclusion Based on the inspection results, the inspectors concluded that the three plant review organizations, OSLO, NSRG and ISEG, were effective in performing assigned reviews, investigations and evaluations. Support and assistance to plant management in the resolution of problems was very good. Members of the groups were experienced and were aggressive in pursuing plant problems and issue E8 Miscellaneous Engineering issues This section describes the review, action and status of selected items which had been identified in previous NRC inspection E (Closed) Inspection Follow Uo item 50-341/95009-02: Questionable Emergency Equipment Cooling Water (EECW) Heat Exchanger Rating This IFl was opened to track the licensee's efforts to determine why the UFSAR specified the maximum flow through the EECW heat exchangers to be 1450 gpm but the surveillance tests were run at flow rates of 1500 to 1650 gpm. The licensee's proposed corrective actions were to replace the EECW heat exchanger during the next refueling outage (in 2000) and to revise the UFSAR to reconcile the flow rates. The inspectors l concluded that the planned corrective actions were sufficient to resolve the original l 18 l
I
. - - .... - - - _ - . - _ - -
,4 .
,
, ;
i
concem. The inspectors further deemed that the planned actions were conservative, due to the actual flow rates that the heat exchanger had experienced at the time and due to the decreased potential for erosion due to the system being a closed system using relatively clean water. Because the corrective actions are acceptable and this item is incorporated into the licensee's corrective action system (CARD 98-12512), NRC will no l longer track this IFl. This item is close E8.2 (Closed) Violation 50-341/97005-01: Failure to maintain the diesel fire pump engine !
speed within acceptable limits. The inspector reviewed the response to the violation and l verified that adequate actions were taken. This item is closed, l
. .. i E8.3 (Closed) Unresolved item 50-341/97005-03: Licensee Review of Lubricating Levels for Rotating Equipment. The actions that had been taken to address this issue were l r
acceptable. Additional appropriate actions were scheduled for completion before the l end of June,1999. This item is close )
l E8.4 (Closed) Violation 50-341/95005-04: Inadequate Engineering Evaluation of Non-Safety l Related Parts. The inspector reviewed the response to the violation and verified that !
adequate actions were taken. This item is close E8.5 (Closed) V.olation 50-341/97011-02: The Updated Final Safety Analysis Report and the i Technical Specifications were inaccurate regarding the Condensate Storage Tank .
volum j
This violation was written because the UFSAR and TS did not account for unusable l water (due to standpipe and vortex concems) in the condensate storage tank when I specifying the water available to the core spray and high pressure coolant injection l systems. This concem was originally identified during the Fermi operational safety -
inspection (50-341-96201). Following issuance of the violation, the licensee confirmed that the TS and UFSAR values were non-conservative. On March 27,1998, the licensee submitted a TS amendment request to the NRC, correcting the TS values. The licensee stated the UFSAR would be revised, once the TS amendment was received. Because the corrective actions are acceptable and this item is incorporated into the licensee's corrective action system (CARD 97-11486), the violation is close E8.6 (Closed) Escalated Enforcement item 50-341/98005-01: Failure to Demonstrate Reactor Protection System Trip Units Within Response Time Limit. This potential violation was determined to be the direct result of the inadequate 10 CFR 50.59 eva' ution identified in E8.9; therefore, no Technical Specification violation occurred. This item is close ~ E8.7 (Closed) Escalated Enforcement item 50-341/98005-02: Failure to Demonstrate '
,
Isolation Trip Within Response Time Limit. This potential violation was determined to be the direct result of the inadequate 10 CFR 50.59 evaluation identified in E8.9; therefore, no Technical Specification violation occurred. This item is close !
. _ - - - . -, . _ . - .. .-
. . . . . _ _ _ _ _ _ _ _ . . _ _ _ _ - . _ _ . . _ _ . . _ . . _ _ _ _ . _ . _ _ _
,,
..
-
!
!
E8.8 (Closed) Escalated Enforcement item 50-341/98005-03: Failure to Demonstrate ECCS f Trip Function Within Response Time Limit. This potential violation was determined to be i the direct result of the inadequate 10 CFR 50.59 evaluation identified in E8.9; therefore, i no Technical Specification violation occurred. This item is close E8.9 - (Closed) Escalated Enforcement item 50-341/98005-04: Prior NRC Approval was Not !
Sought for Changing Technical Specification Requirements. In a letter to the liensee, l dated August 5,1998, the NRC acknowledged that the licensee identified the inadequate !
10 CFR 50.59 evaluation in March of 1997 and reported the issue to the NRC as !
required. The corrective actions documented in licensee event report 97006, Revision 1 !
'
and as communicated at the May 6,1998, meeting at the Fermi plant, were acceptabl Accordingly, the NRC dispositioned this non-repetitive, licensee identified and corrected violation as a non-cited violation, consistent with Section Vll. B.1 of the enforcement policy. This item is close ;
I II. Management Meetings !
V1 Exit Meeting Summary i The inspectors presented the inspection results to members of licensee manage. ment in an exit ,
meeting on January 29,1999. The inspectors noted that no documents provided during the !
inspec; ion were identified as proprietary. The licensee acknowledged the information presented l i
and agreed that no proprietary information was provided to the inspectors,
!
!
I
!
I
!
!
I
!
i
!
}
.
!
!
!
20 !
!
!
l i
.
. - . . , . , - . , . , ,_,..-,v - ,..m -,,. ,,
,.
.I
.
PARTIAL LIST OF PERSONS CONTACTED Licensee D. Bergmooser, Electrical Supervisor, System Engineering T. Bergner, Director, Organization Development J. Bragg, Nuclear Quality Assurance L. Collins, Electrical Plant Support Engineering R. DeLong, Superintendent System Engineering T. Dong, NSSS Supervisor, System Engineering Q. Duong, Acting Electrical Supervisor, Plant Support Engineering P. Fessler, Assistant Vice-President, Operations K. Howard, Director, Plant Support Engineering J. Moyers, Director, Nuclear Quality Assurance W. O'Connor, Assistant Vice-President, Nuclear Assessment J. Pendergast, Nuclear Licensing Compliance N. Peterson, Director, Nuclear Licensing ,
G. Scarfo, Designi Supervisor, Plant Support Engineering P. Smith, Nuclear Licensing Compliance S. Stasek, Supervisor, independent Safety Engineering Group
.
NRC S. Campbell, Acting Senior Resident inspector J. Larizza, Resident inspector l
l l
l
i l
l
!
I
l
, ,- . - . . . . . - ._ - - . - - - - - - . - - . . ~ . - . .- .. . ~ - .- . . ...- ,
,. g *
' -
,
t i
4 l l
INSPECTION PROCEDURES USED l
!
IP 37001: 10 CFR 50.59 Safety Evaluation Program j
,
IP 37550: Engineering l lP 37700:l Design Changes and Modifications :
. IP 40500: . Effectiveness of Licensee Controls in Identifying, Resolving and Preventing [
Problems iP 92903: Followup- Engineering
!
i ITEMS OPENED, CLOSED, AND DISCUSSED l
i OPENED i
'
50-341/99002-01 VIO Errors were made in three design calculation /99002-01 URI Possible failure of emergency lights to meet appendix R f;
requirement !
CLOSED f 1 50-341/95009-02 'IFl Questionable Emergency Equipment Cooling Water (EECW) Heat !
Exchanger Rating i 50-341/97005-01- VIO Failure to maintain the diesel fire pump engine speed within ,
'
acceptable limit /97005-03 URI Licensee Review of Lubricating Levels for Rotating Equipmen /95005-04 VIO Inadequate Engineering Evaluation of Non-Safety Related Part !
50-341/97011-02 VIO The Condensate Storage Tank volume was inaccurate in the 1 Updated Final Safety Analysis Report and the Technical Specification /98005-01 eel Failure to Demonstrate Reactor Protection System Trip Units Within Response Time Limi /98005-02 eel Failure to Demonstrate isolation Trip Within Response Time Limi /98005-03 eel Failure to Demonstrate ECCS Trip Function Within Response Time Limi /98005-04 eel Prior NRC Approval was Not Sought or obtained for Changing Technical Specification Requirement DISCUSSED No items identified in previous NRC inspections were discussed without closin .
g _._!. , . - - - .~ , -
E 1
-
,.
.
!
LIST OF DOCUMENTS REVIEWED ,
l
The following is a list of licensee documents reviewed during the inspection, including i documents prepared by others for the licensee. Inclusion on this list does not imply that NRC inspectors reviewed the documents in their entirety, but, rather that selected sections or portions i of the documents were evaluated as part of the overallinspection effort. inclusion of a e document in this list does not imply NRC acceptance of the document, unless specifically stated i in the body of the inspection repor '
I Procedures MLS10 Regulatory Action and Commitment Tracking, Revision 6 MES02 Design Configuration Management, Revision 1 l
MES11 Technical Service Request, Revision 9 MES12 Preforming Temporary Modifications, Revision 4 i MES16 Temporary Power, Revision 1 l MES19 Preparation and Control of Engineering Design Packages, Revision 7 MES20 Implementation of Modifications, Revision 7 MES27 Verification of System Operability, Revision 5 MES28 Evaluation of Plant System and Component Performance, Revision 6 ,
'
MES29 Documentation and Reporting of Operating Transients and Cycles, Revision 3 MLSO4 Operating Experience Program, Revision 6 MLS05 Notifications / General Regulatory Reporting Requirements, Revision MLS06 Interfacing with regulatory Agencies and Industry Organizations, Revision
MLS07 Preliminary Evaluations and 10 CFR 50.59 Safety Evaluations, Revision 11 i MLS11 Post Event Investigations, Revision 6 MLS13 Independent Safety Engineering Group, Revision 3 i MQA02 Fermi 2 Quality Assurance Conduct Manual Revision 7,6/2/98, Internal i
'
Audits and Surveillances Surveillances l 24.203.01," CSS Discharge Piping Filled and Valve Position Verification," Revision 2 ;
24.203.02," Division 1 CSS Pump and Valve Operability, and Automatic Actuation," 1 Revision 2 .203.03," Division 2 CSS Pump and Valve Operability, and Automatic Actuation,"
Revision 2 .203.04, " Core uray Valve Operability and Position Verification Test," Revision 2 .204.01, " Division 1 LPCI and Suppression Pool Cooling / Spray Pump and Valve Operability Test," Revision 3 l 24,204.02, "RHR Valve Lineup and System Filled Verification," Revision 2 .204.03, "LPCI Simulated Automatic Actuation Test, Response Time Test, and Valve i Operability Test," Revision 2 I
!
r
,,
,
24.204.04, "RHR Shutdown Cooling Valve Operability," Revision 2 .204.05," Division 1 and Division 2 RHR Valve Position Indication Verification Test,"
Revision 2 .204.06," Division 2 LPCI and Suppression Pool Cooling / Spray Pump and Valve Operability Test," Revision 3 .203.002," Division 1 CSS Pump and Valve Operability and Automatic Actuation, Revision 28 24.203.003, * Division 2 CSS Pump and Valve Operability and Automatic Actuation, Revision 30 24.204.006," Division 2 LPCI and Suppression Pool Cooling / Spray Pump and Valve Operability Test " Revision 42 24.307.011 " Emergency Diesel Generator 12 - ECCS Start and Load Rejection Test and Logic Functional Test of Bus 64C Breaker," Revision 29 24.307.013, " Emergency Diesel Generator 14 - ECCS Start and Load Rejection Test and Logic Functional Tests of Bus 64F Breakers," Revision 31 35.304.001, "480 Volt Unit Substation," Revision 25 35.304.009, " Refurbishing 600 Volt K-Line Air Circuit Breakers," Revision 22 35.304.010. " Refurbishing 5HK Air Circuit Breakers," Revision 1
35.306.008, " Motor Control Center Load Compartment," Revision 37 '
35.309.001,"130/260 Volt Battery Charger Testing, Calibration and General Maintenance," Revision 32 35 318.003, " Power Shield - 480 Volt Circuit Breaker Solid State Trip Testing," Revision l 27 l 35.318.004, " Testing of CA and CA-16 Differential Relays," Revision 23 1 35.318.006, " LAC 53A, B IAC6GB Overcurrent Relays," Revision 21 35.318.007, " Time Delay Relays," Revision 22 (
35.318.014, " Medium Voltage Switchgear Breaker and Relay Control," Revision 25 35.318.015, *PJC 11 AV and PJC 12D Overcurrent Relay Testing," Revision 22 35.318.017," Inspection and Testing of Multi-Contact Auxiliary Relays," Revision 26 35.318.023, "ABB Low Voltage Circuit Breaker Solid State Trip Device - Sensor Polarity Verification," Revision 0 42.302.009, " Calibration and Functional Test of Division 2 4160 Volt Bus 65E Undervoltage Relays ," Revision 23 42.307.001," Logic System FunctionalTest of Division 1 EDG ECCS Emergency Start Circuits and Auto Trip / Bypass Circuits, Revision 25 42.307.002," Logic System Functional Test of Division 2 EDG ECCS Emergency Start !
Circuits and Auto Trip / Bypass Circuits Revision 24 42.307.007," Calibration and Functional Test of Division 14160 Vc' aus 64B Undervoltage Relays," Revision 24 42.309.001, " Division % Weekly 130/260 Battery Check," Revision 27 42.309.002, " Division % Quarterly 130/260 VDC Battery Check," Revision 27 42.309.003, " Division 1 18 Month 130/260 VDC Battery Check," Revision 29 42.309.004, "130 VDC ESF Battery Charger load Test," Revision 24 42.309.005, " Division % 130/260 Gattery Capacity Test," Revision 24 42.309.006," Division 218 Month 130/260 VDC Battery Check," ReUsion 23
. l
- '
. )
!
.
Modification Packages EDP-05173 Add ATWS Trip to Recirculation Pump Drive Motor Breakers, Revision 0 I
EDP-12853 Obsolete N21 System GMAC Controller Replacement
)
EDP-13751 - Reactor Water Level Instrumentation Reference Leg Backfill Lines !
EDP-26834 H2/02 Injection Systems for Implementation of Hydrogen Water l Chemistry ,
EDP-26835 H2/02 Supply Facility for implementation of Hydrogen Water Chemistry '
EDP-26959 Replacement of Class ,1E (Division 11) Power Battery ;
EDP-27049 Reactor Water Cleanop System Regenerative Heat Exchange Bypass -
_
Line, Revision 0 EDP-27275 Replacement of E11N021 A with ITT Barton Model 581 A-2 Switch I EDP-27413 Removal of EOC 98-0008, Digital upgrade to provide fuel-zone Water j Level Correction for Off-calibration pressure conditions, Revision 0 '
EDP-27422 Pressere Locking Mitigation Modification, Revision l EDP-27424 Pressure Locking Mitigation Modification, Revision ;
EDP-27962 RBCCW System PCV/TCV Modification, GSW System, Revision <
EDP-27966 RBCCW Heat Exchanger Tie-in Tees Support Revision, Revision !
EDP-28272 Emergency Diesel Generator Fuel Oil Storage Tank R3000A01,2,3&4 Fuel Oil Sampling Capacity EDP-28306 Knife Switch Installation for Undervoltage Protection Scheme Testing EDP-28747 Overpressure Protection of Containment Penetrations per GL-96-06, !
Revision !
EDP-28769 Modification of Containment Pressure Sensing Lines, Revision ;
EDP-28998 Addition of RHR Min Flow Alarms and change Setpoint for Time Delay !
Relays to open Min Flow Valves, Revision 0 EDP-29024 ECCS Suction Strainer Replacement, Revision EDP-29195 Motor and Anti-Cycle Logic Change for Containment Spray Throttle Valve E1150F016A EDP-29319 Motor Replacement for E4150F042 to increase torque / thrust capability pursuant to Gl 89-10 requirements, Revision 0 EDP-29317 Undersized Motor in MOVs E4150F004 and E4150F041 (From 25 to 40ft-Ib Motors) ;
EDP-29348 Modification of the Personnel Air Lock Nitrogen Inerting and Purge Lines, Revision EDP-29354) Reactor Feed Pump turbines Dual Speed Limiter Setpoints Valuri Revision 0 EDP-29365 Addition of Quick Disconnects (ODCs) at MSIV Limit Switches EDP-29428 Replace Existing Target Rock Solenoid Valves P34F401 A and B with Newer Target Rock Models EDP-29789 Installation of Larger RBCCW Make Up Tank Pressure Relief Valve EDP-29792 EECW TCV and Controller Replacement, Revision 0 EDP-29900 Reset of RCIC Turbine Speed Ramp Generator Signal Converter E51K201
. . - - . . - - .- - -- .- .-.
. g
f i
!
li Temporary Modifications i 96-0019 Installed EDG 14 Inboard Bearing Temperature Indication 97-0006 Installed EDG 11 Inboard Bearing Temperature !idication 97-0019 Raise the South RWCU Pump (G3303C001B) seal plate high temperature alarm setpoint from 250 F to 304 F -
98-0008 Install taps and monitoring equipment on the North and South Reactor '
Feed pump Steam Supply and drain lines *
98-0016 To Install temporary instrumentation (accelerometers, strain gauges, position transmitters, and pressure transducers) to monitor the operation of the HP control valves during power operation 98-0022 Install temporary instrumentation on the Reactor Recirculation Control System (RRCS), Revision A 99-0003 Use spare position of #1 of MPU #3 Cabinet #2 to supply power to MPU
- 3 Cabinet #2 position 5 loads (H11P906B)
I ConCtion Resolution Assessment Documents (CARDS)
97-07570, Check Valve Leaking 97-10306, Found Mispositioned Valve During Rounds,09/09/97 97-10351, Failure to Complete Required Procedure Steps,09/09/97 97-10619, Potential Operation Outside the Design Basis Analysis,10/30/97 l 97-10968, Near Miss: Loss of Shutdown Cooling,10/04/97 1 97-11035, Concems with SE 97-0015 Rev 0, Rev 1, & Rev 2,10/03/97 1 97-11316, Safety Relief Wlve Failure to Lift at Setpoint,10/13/97 97-11415, Foreign Material Exclusion Area Discrepancies,10/10/97 -
97-11486, NRC Notice of Violation on Condensate Storag* Tank Volume,10/31/97 97-11680, Missed Surveillance for Division 1 Control Air Cc riessor Auto Start Function, l 10/14/97 97-11705, Reactor Pressure Vessel Water Level instrumentation Referenco Leg Backfill System,10/18/97 97-11821, inaccurate Log Keeping of Equipment Run and Stop Times impacts Maintenance Rule Performance Criteria Calculations,12/11/97 97-13438,10CFR 50.59 PE for 23.137 Doesn't Address impact on Main Steam isolation Valve Leakage Control System,11/12/97 l
'
93-00180, Main Contactor for MCC 72P-3D Position 2D Was Chattering Excessively 98-01994, Maintenance Rule Functional Failure of an ELU 98-02035, Voltage Reading Out of Specification for UPS Uriit 98-10276, Documentation Discrepancies Regarding Maximum Flow Rate Through RHR Heat Exchanger Shell Side,02/04/98 98-10325, DER Closed with Incomp!ete Corrective Actions (DER 96-1779),12/03/96 98-10781, RHR Head Spray Piping Not Downgraded when EDP Worked,01/30/98 98-11039, Maintenance Rule Potential Monitoring Violation,02/18/98 I 98-11053, High Mild Steel Corrosion Rates Indicated in RHR Service Water,02/02/98 98-11337, Secondary Heat Balance Errors,03/31/98 98-11360, Potential Violation of 10 CFR Part 73 Appendix B,04/09/98 I 98-11438, Discrepancies Discovered During Drywell Walkdown (DER 97-0647),04/30/97 l 26 !
,.
,
98-11730, Maintenance Ru!e Classification of Main Turbine Control as (a)(1) (DER 96-0192), I 03/20/98 I 98-11751,10CFR Part 21 Determination Made lay Maintenance Support not Licensing, !
02/20/98 1 98-11908, Third Failure of Temperature Switch R30NA04D !
98-11910, Third Failure of Temperature Switch R30NA03B !
98-11990, Temperature Control Switches Found Out-of-Tolerance 98-12413, Convert DER 96-1484 to CARD: SRV Failure to Lift at Set Pressure,10/25/96 l 98-12492, NO Piping and Components connected to Drywell Airlock (Transfer of DER 97-0806 l to CARD) l 98-12512, UFSAR EECW Heat Exchanger Flow (DER 95-0576),08/09/95 98-12583, Write Licensing Change Request for Closure of DER 97-0549,04/11/97 98-13167, Recordable Work Related Injury (Thumbtack in Palm),04/06/98 !
98-13756, Potential for overpressurizing EECW 98-14331, EDP 28140 Surveillance Observations - Testing and implementatien i 98-14332, EDP 28140 Surveillance Observations - Operations Procedures 98-14333, EDP 28140 Surveillance Observations - Programmatic issues '
98-14S92, Flow Swings in Moisture Separator Reheater Steam Flow,07/20/98 98-14693, Water Hammer oti High Pressure Coolant injection (HPCI) System,03/28/98 l 98-14768, Drywell Cooler Leak Caused Significant Drywell Pressure Increase,05/27/98 !
98-15158, Wire From Overvoltage Relay Contact Was Found on incorrect Terminal l 98-15250, Main Condenser North Hotwell Level Increase. 07/08/98 l 98-15402, Post Maintenance / Mcdification Testing Assessment 98-15947, Manual Reactor Scram Due to Reactor Power Perturbations of 12 - 15%, Peak-to- 1 Peak,09/0498 l
'
98-16353, Sudden Change in Turbine Control Valve Position and Reactor Power Spike During Power Ascension,07/25/98 98-16439, Loss of Busses 65E and 72E During Scheduled Surveillance Test,09/08/98 98-16612, Three Consecutively Performed Calibrations Had As-Found Values Out of Calibration,08/05/96 98-17187, improper Tracking and Meterial Control of SRVs,09/23/98 98-17744, Work Performed on Recirculation Motor without Work Request on Job, 09/14/98 98-18350, Drywell Shell interior Surfacing, 10/14/98 98-18389, SRV Body / Base 391 Installed in Error instead of Base Body S/N 334,10/19/98 98-18420, Operability Determinations, 10/12/98 98-18643, Data Errors in Local Leak Rate Test Surveillance Packages,09/30/98 98-18661, Division 1 RHR Heat Exchanger Flow Rate Exceeded 10,700 GPM,10/09/98 98-18695, Incorrect Tolerance Used to Calibrate Undervoltage Relays 98-18726, HPCI Injection Line Insulation Not Removed in Accordance with EDP 13978, 10/04/98 98-18735, Five SRVs Exceed Set Point Tolerance of 13%,10/07/98 98-18788, Reactor Feed Pump Mini Flow Vatve Oscillating,10/30/98 98-18887, Feedwater Check Valve Indicates Dual with No Feed Flow to the Reactor,10/16/98 98-18895, Potential Unsafe Condition in Moisture Separator Reheater Not Recognized or Responded To Correctly,10/07/98 98-19015, SRV Base Body Leaking Water, 10/15/98 98-19037, SRV Leaking Flange, Main Body, 10/14/98
,,
'
98-22099, Data Left Outside of Acceptable Tolerance on Surveillance Test, 10/28/98 98-22190, North Reactor Feed Pump Mini Flow Valve Did Not Open When it Should,10/27/98 98-22314, At Rated Flow, Feedwater Check Valve Indicates Closed, 11/04/98 98-22422, Outboard Feedwater Line B Check Varve Has Steam Leak,11/11/98 98-22869, Safety Evaluation 98-0031 Discrepancies, 11/18/98 98-22904, Reactor Feed Pump Mini Flow Valve Failed to Close, 11/19/98 98-23319 Review Evaluation of Engineering Support for Older Engineering-Restrained Work Requests, 12/18/98 98-23680, Engineering Review of Nuclear Training Procedures and Qualification Data is Difficult 98-23279, Engineering Field Observation of Engineering Personnel Training and Qual Program STOPD 10?/102 98-14294, Technical Specification Transient Count on the Reactor Pressure Vessel,06/09/98 99-11580, Multiple Peaker Problems, 01/02/99 '
99-10431, Deviations in Core Spray System Hydraulic Analysis Design Calculations l Miscellaneous Documents and Records Deviation Event ReDorts DER 96-1232," Determine Affect on Plant if Instrument Tube Breaks Outside Containment without Isolation due to Break and Loss of Instruments. Determine i Reportability Based on Above," dated October 1,199 i DER 97-0549,"ECC3 is Not Considered Inoperable During Testing and Other Abnormal l Modes," dated April 11,199 DER 97-0806,"NQ Piping and Components Connected Directly to the Drywell Airlock !
Which is a ASME Class 2 Component and Its impact on the Leek Tightness of the l Exterior Airlock Boundary," dated May 21,199 J Effectiveness Reviews Effectiveness Review for CARD 97-10306,08/31/98 Effectiveness Review for CARD 97-10351,02/12/98 Effectiveness Review for CARD 97-11415,12/01/98 Effectiveness Review for CARD 97-11680,04/17/98 Effectiveness Review for CARD 97-11821 (undated)
Effectiveness Review for CARD 98-11039,01/06/99 Effectiveness Review for CARD 98-11360,11/06/98 Effectiveness Review for CARD 98-15250,07/16/98 10 CF50.59 Safety Evaluations SE 93-0029 Add ATWS Trip to Recirculation Pump Drive Motor Breakers, Revision 0 SE 93-0036 Reactor Water Level Reference Leg Backfill Lines, Revision 0 SE-93-0043 Repiace Obsolete GMAC Controllers l
l 28 l l
I
,
'
.* I
.
SE 95-0024 For Hydrogen Water Chemistry Modification EDP-26834,26835,27352, 27353, TRS-27567, IPTE 95-04, SOE95-12, Re SE 95-0051 Bypass line around Regenerative Heat Exchanger on RWCU for Decay Heat Removal, Revision 1 SE 96-0037 EDP-27966 Will Install Tie-in Tees and Isolation Valves on GSW and RBCCW During the RF05 Outage, Revision SE 96-0071 EDP-28141 Will Add a Third RBCCW 50% Capacity Heat Exchanger, including All Necessary Subcomponents and Accessories, Revision SE 96-0114 During the Investigation of DER 96-1232, it Was Determined that the Configuration of the Instrument Lines Associated with Penetrations X-47c '
and X-206a Does Not Meet the Intent of the Design Criteria as Described in Note 12 of UFSAR Table 6.2-2, Revision SE-97-0055 Replacement of RHR Division i Drywell Spray Outboard Isolation Valve :
SE-97-0134 Emergency Diesel Generator Fuel Oil Storage Tank Sampling Capability SE-98-0007 Replacement of Division ll 260/130 VDC Station Battery SE 98-0016 Replacement of the Residual Heat Removal (RHR) and Core Spray (CS) ,
System Torus Suction Strainers, Revision '
SE 98-0018 EDP-29348 Cuts the Personnel Air Lock Inerting Lines, and Caps One and Plugs the Other. An ASME Valve is Added to One of the Lines to Allow ISI/ PEP Group to Perform Their Leak Rate Test on the Air Lock, Revision SE 98-0026 Installation of Quick Disconnect Connector on MSIV Limit Switches, Revision 0 SE 98 rd31 Install Larger Capacity Pressure Relief Valve on RBCCW Makeup Tank, Revision SE 98-0032 Addition of Density Compensation to Fuel Zone Rx Water Level Instrument, Revision 0 !
SE 98-0037 Rupture Disk Over Pressure Protection is Added to Two Containment 1 Penetrations to Prevent Thermal Overpressure as Described in GL 96-06, I Revision 1 I SE 98-0038 EECW TCV and Controller Replacement, Revision 0 SE 98-0055 Reset RCIC Turbine Speed Control, Revision 0 SE 98-0076 Restrictions on Operatian of the Drywell Coolers Subsequent to a LOCA and Reasons for Restrictions, Revision SE 98-0087 RPV Bottom Head Drain as source of RWCU Suction, Revision 1 SE 98-0110 UFSAR Validation Project Identified Discrepancy, Revision 0 Work Recuests WR R032960202 Test MCC and inspect and Test Battery Charger
'VF.3 33960110
-
Test MCC and Inspect and Test Battery Charger iR;34951003 Test MCC and Inspect and Test Battery Charger vt * R035970115 Test MCC and Inspect and Test Battary Charger WR R036970115 Test MCC and Inspect and Test Battery Charger WR S472940215 Perform Maintenance and Test of Medium Voltage Swgr- Bkr, Relay Control and Transformer WR S882930223 Perform Test on Medium Voltage Breaker and Relay Control
l
- ,,'*
.
WR V128960729 Refurbish 4160V Breaker 64B WR V241960730 Refurbish 480V Breaker 72EA-1B l
Nuclear Quality Assurance Audit Reportg 97-0110 Evaluation and Corrective Action Program J7-0118 Identification and Control of Materials, Parts and Components; and Shipping, Handling and Storage l 97-0123 Pre-Outage Preparation for Midcycle '97 Outage 97-0129 Evaluation and Corrective Action Program 98-0105 Evaluation and Corrective Action Program j
Fuclear Quality Assurance Surveillance Reports ;
97-0239 Division 1 and Division 2 Main Steam Safety Relief Valve (SRV) Mid-cycle Outage Surveillance 97-0244 Evaluation of CARD Tag Removal Practices for Compliance with MWC02 97-0251 Evaluation of CARD Tag Removal Practices for Compliance with MWC02 98-0117 Modification Process Control During RF06 98-0207 Evaluation of CARD Tag Removal Prcetices )
98-1002 Operational Assessment l 98-1004 MOV Testing Using Liberty Technologies Inc. Motor Power Monitor (MPM)
98-1007 Supplemental Cooling Chilled Water Modification EDP-28140 98-1011 MCC Bucket Replacement Project TSR 29429 98-1012- NQA Review of Turbine Control Valve Rework l 98-1013 NQA Review of the Identification of Post Maintenance and Post Modification Test Requirements 98-1016 Feedwater Check Valve B2100F076B Pressure Seal Rework Nuclear Quality Assurance Special Surveillance Reports 97-1004 Operational Assessment 97-1011 Operational Assessment 97-1012 (Not titled)
98-1002 Operational Assessment Calculations 95-D-546, " Maximum Flow Evaluation EECW Heat Exchangers" (Yuba Heat Transfer),
10/30/95 SL-5965, " Flow induced Vibration Analysis Report for Fermi 2 EECW Heat Exchangers" (Sargent & Lundy),01/05/98 l
!
l l 30 ;
!
!
.
.,;p _
P l
!
,
Memos ;
" Analysis of Error Free Operating Day Reset DERs", K. Tyger to site management, !
07/17/97'
" Evaluation of Error Free Days", J. Moyers to site management,06/12/98 ;
" Evaluation of RF06 Error Free Days", J. Moyers to site management,01/20/99 Miscellaneous i
I QP-ES-102 Nuclear Generation Selection, Training and Qualification Program }
Description, Revision 7,6/98, Management and Supervision QP-ES-105 Nuclear Generation Selection, Training and Qualification Program i
. Description, Revision 14,6/98, Engineering Support Personnel '98-018 ISEG Report, Review of Fermi 2 Post-Maintenance Test Processes i
' Technical Specifications 3/4.5, " Emergency Core Cooling Systems," and 3/4.6.1,
" Primary Containment," and Associated Technical Specification Bases, Amendment N '12 l
,
i
UFSAR Section 6.3, " Emergency Core Cooling Systems," Revision LCR 97-166-UFS,"EDP 29024 Replaces Basket-Type ECCS Suction Strainers with Stacked Disk-Type Strainers," Revision !
LCR 98-054-UFS, "EDP 28747 Added Overpressure Protection per GL 96-06 to Drywell Penetrations X-18 and X-19," Revision ,
LCR 98-135-UFS, "UFSAR Validation Project identified Discrepancy," Revision j LCR 98-165-UFS,"EDP 29024 Replaced the ECCS Suction Strainers that are Designed to Accommodate Paint Debris," Revision DC-0204, " Sizing Restricting Orifice Diameters and Thicknesses," Revision DC-0230, " Core Spray System," Revision DC-0367, " Design Calculatione for the RHR System," Revision DC-0885,"ECCS Suction Line Air Injection," Revision DC-5079, "RHR and CS Tech. Spec. Surveillance Pump Discharge Pressures," Revision DC-5141, "LPCI and Core Spray Flows for OPL-4," Revision Non Duke Engineering and Services Letter VT5900.019, " Review of Low Pressure ECCS NPSH Calculations," dated August 1,199 J l'
USNRC Letter, "ECCS Setpoint Issue," dated June 27,198 Detroit Edison Letter NRC-89-1075, " Response to NRC Request for information on Flow and Pressure Setpoints for Low Pressure Emergency Core Cooling Systems," dated i August 31,198 ,
l
'
.
.
--
-
-
e LIST OF ACRONYMS USED BOP Balance-of-Plant CARD Condition Assessment Resolution Document CS Core Spray CSS l Core Spray System i-DC Design Calculation j ECCS Emergency Core Cooling System !
EDP Engineering Design Package l EECW Emergency Equipment Cooling Water ELU Emergency Lighting Unit ;
GPM Gallons Per Minute '
HPCI High Pressure Coolant injection l IEEE Institute of Electrical and Electronic Engineers ,
IFl inspection Followup l'em '
IN Information Notice i ISEG Independent Safety Engineering Group LPCI Low Pressure Core injection NQA Nuclear Quality Assurance :
OSRO On-Site Review Organization {
PDR Public Document Room i PM Preventive Maintenance !
TS Technical Specifications !
UFSAR Updated Final Safety Analysis Report 3 i
,
i i
.
i
!
r-
.
i
'
,
i s
i
<
)
j
'
.