IR 05000341/1985024
| ML20127M407 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/21/1985 |
| From: | Chrissotimos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20127M386 | List: |
| References | |
| 50-341-85-24, IEIN-84-01, IEIN-84-1, NUDOCS 8507010218 | |
| Download: ML20127M407 (8) | |
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- 4 U. S. NUCLEAR REGULATORY COMMISSION
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Report No..50-341/85024(DRP)
Dockef. No. 50-341 Operating License No. NPF-33 s
/;Licensee: Detroit Edison > Company
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2000 Second Avenue
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Detroit, MI 48226
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M Facil"ity Name:
Fermi 2 4, "
Inspection At:
Fermi Site, Newport, MI
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Inspection Conducted:
May 1-31, 1985
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'Inspettoks:
P. M. Byron
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M. E. Parker
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D.C.Jpp1 l
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N.-J.
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Projects Section 1D Date
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Inspection Summary Ins 6ictiononMay 1-31, 1985 (Report No. 50-341/85024(DRP))
< Areas Inspected:
Routine, unannounced inspection by resident inspectors of licensee actionJon previous inspector identified items; actions taken by the
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licensee of BWR facilities with Mark I and Mark II containments in response to GE SIL No. 402; surveillance testing c.nd calibration program; maintenance M piogrSEf operMtional safety verification; monthly maintenance observation;
-: fire protection; and independent inspection.
The inspection involved a total
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ofc 132 inspector-hours onsite by three NRC inspectors,. including 19 inspector-c M.hnurs onsite during off-shifts.
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[desult w No items of noncompliance, deviations, or significant safety issues
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. ere identified.
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>,. 8507010218 850626 PDR ADOCK 05000341 Q
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DETAILS 1.
Persons Contacted
- F. Agosti, Manager, Nuclear Operations
- L. Bregni, Licensing Engineer G. Clark, Shift Supervisor J. DuBay, Director, Planning and Control 0. Earle, Supervisor, Licensing R. Eberhardt, Rad-Chem Engineer
- E. Griffing, Assistant Manager, Nuclear Operations
- W. Jens, Vice president, Nuclear Operations W. Kaczor, Director, SAFETEAM S. Leach, Director, Nuclear Security J. Leman, Maintenance Engineer L. Lessor, Assistant to the Superintendent
- R. Lenart, Superintendent, Nuclear Production R. Mays, Director, Project Planning
- W. Miller, QA Supervisor, Operational Assurance J. Nyquist, Assistant to Superintendent, Nuclear Production
- G. Overbeck, Assistant Plant Superintendent, Startup J. Plona, Technical Engineer E. Preston, Operations Engineer W. Ripley, Startup Director C. P. Sexauer, Nuclear Production Administrator
- G. Trahey, Director, Nuclear QA
- Denotes those who attended the exit meetings.
The inspectors also interviewed others of the licensee's staff during this inspection.
2.
Followup on Inspector Identified Items a.
(0 pen) Open Item (341/84-39-01(DRP)):
Accessibility of valves for serviceability and manual operation of safety-related valves during abnormal conditions. This item identified numerous inaccessible safety-related valves that would require mobile platforms to operate, inspect, and maintain the valves.
The licensec conducted a review and has developed a list of 217 safety-related valves that should be accessible.
The following method was applied for the review:
All Abnormal Operating Procedures and Emergency Operating
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Procedures were reviewed to determine those which required manual operation of valves during abnormal or emergency conditions.
All safety-related systems were reviewed with regard to the
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ALARA considerations on serviceability of safety-related valves.
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Valve Accessibility Sheets were made, listing each applicable
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i valve, the location, and the necessary requirements for accessibility.
Each valve was physically walked down in accordance with the
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Valve Accessibility Sheets.
Of the 217 valves that were observed, 69 or 32% have accessibility problems.
The licensee has developed a program to provide access to these valves:
Catwalks and platforms are currently being designed by DECO
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Engineering for the top of the torus area.
This applies to six of the valves.
Ladders and air hoists are currently being ordered for valves
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that require such equipment.
The equipment will be placed in service as required.
Engineering Evaluation Requests (EER) and Shop Orders are
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being written for the design and construction of the required equipment and will be implemented when available.
EER's have been written for 22 valves and are now being prioritized.
Upon completion of this program, the licensee will demonstrate adequate accessibility to these safety related valves.
Pending licensee completion and subsequent review by the inspectors of this program, this item remains open.
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(Closed) Open Item (341/84-40-03(DRP):
Incorporating Human Factors Commitments in Emergency Operating Procedures (E0P's).
During a review of the E0P's, the inspectors identified several areas of the procedures that needed improvement, such as ensuring the human factors commitments of the BWR Owners Group were met; referencing figures which were not identified; improving clarity of figures; identifying typographical errors; and clarifying procedural steps.
A re-review of the E0P's (29.000 series) identified that the licensee has addressed the inspectors' concerns and has redrawn all figures to make them more compatible with control room indications.
Review of DECO letter from L. C. Lessor to L. P. Bregni dated April 10, 1985, identified that the licensee has corrected the heat capacity level limit figure in regard to downcomer submergence, and redrawn figures using control room ranges and divisions.
This item is considered closed.
c.
(Closed) Open Item (341/85013-01(DRP)):
Checklist of Control Console.
Review of SER Item I.e.2., Shift Relief and Turnover Procedures, identified that the licensee's Administrative Procedure 21.000.01, " Shift Operations and Control Room," did not include a specific check of the control console for shift and relief turnover.
The shift relief checklist and the Engineered Safety Features (ESF)
checklist do contain general statements that ESF systems are aligned
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O and operable, but the checklists do not meet the criteria of TMI Item 1.c.2(b).
Revision 11 dated May 7, 1985, of Procedure 21.000.01 includes a checklist to satisfy this item.
This checklist will provide specific verification of the control console to assure the availability and proper alignment of systems essential to the prevention and mitigation of operational transients and accidents.
This item is considered closed.
3.
Inspection of the Actions Taken by the Licensees and Applicants of BWR Facilities with Mark I and Mark II Containments in Response to GE SIL No. 402 and IE Information Notice 84-1 The inspectors reviewed the licensee's response and actions recommended in GE SIL in order to satisfy the safety concerns raised as a result of vent header cracks in other BWR containments.
The licensee has responded to the GE SIL in DECO letter EF2-72258 dated September 27, 1984.
The present design of the Nitrogen Inertion System includes automatic trips on low nitrogen flow.
The plant operating procedure also requires an operator to be stationed at the nitrogen equipment building during initial inertion while using the steam vaporizer.
Contingent upon having operators in the equipment building and in the control room, there appears to be adequate status, alarm, and control information available to properly operate the system.
The inspectors therefore conclude that the licensee has adequately evaluated inertion system design and operating procedures as delineated in IE Information Notice No. 84-17 and GE SIL-402.
No items of noncompliance or deviations were identified.
4.
Program Areas Inspected a.
Surveillance Testing and Calibration Program The inspectors walked down approximately 40 instrument racks, most of which were located within the reactor building, and found several instruments with stickers dating back to 1980.
The inspectors determined that the licensee has no requirement or commitment for the upkeep of calibration stickers, however, the inspectors discussed with the licensee that this is a poor practice and may result in future problems.
Calibration for all technical specification related instruments is performed by a surveillance procedure.
Plant Operations Manual (P0M) Procedure 12.000.18, Revision 7 dated April 12, 1985,
" Surveillance Program" describes the administrative guidelines which established the surveillance program at Fermi 2 to ensure the Fermi 2 Technical Specifications surveillance requirements are met.
The inspectors sampled 26 surveillance procedures and found that only one had not been performed.
The one that had not been performed was on an inoperable system and was to be performed prior
to the system's turnover to Nuclear Operations.
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found this program to be adequate and properly implemented.
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No items of noncompliance or deviations were identified in this area, b.
Maintenance Program s
Calibration.for all nontechnical specification related instruments is performed in accordance with the preventive maintenance (PM)
program.
P0M Procedure 12.000.17, Revision 3 dated October 30, 1984, " Preventive Maintenance Program" describes the administrative guidelines used to implement the PM program which schedules the activities necessary to ensure reliable operation of the plant's equipment.
A review of the implementation of the PM program resulted in the
.following concerns:
(1) A PM Task assigned to an individual component is int' ended to prevent or predict component failure prior to its occurren,ce.
Instead of consulting the instruments' vendor or the respec-tive vendor manual, the licensee has established an 18 month frequency for instrument calibration.
The inspectors are concerned that the specified frequency may not be conservative as the licensee has not yet developed a history to determine
.the ability of the individual instruments to maintain adequate calibration.
Additional details on this issue are contained in Inspection Report 50-341/85026(DRS).
(2) To aid the licensee in ensuring the plant's limited human and budget. resources are properly utilized, each PM job is assigned a priority from 1 to 5 (1 being most important to complete and 5 being least important to ccmplete).
Section 6.12 of Procedure 12.000.17 states, "...the Section Head should ensure l
completion of PM Jobs given a priority 1 rating within the assigned month before scheduling PM Jobs given a priority 2 rating; and so on through PM Jobs given a priority 5 rating."
According to the Preventive Maintenance Program PN-21 Status sheet,- 57% of the priority 1 and 2 tasks, and 52% of the priority 3, 4, and 5 tasks were completed during 1984. The
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completion rate for the first four months of 1985 was 61% and 44% respectively.
The PM Program PN-21 Status sheet does not adequately address the completion percentage of priority 1 tasks, but it does demonstrate the failure of the licensee to complete the high priority tasks before scheduling lower priority tasks.
This is considered an unresolved item (341/85024-01(DRP)).
Additional details and concerns on this issue are contained in Inspection Report 50-341/85026(DRS).
(3) The PM program as described in P0M Procedure 12.000.17 requires that all cancelled PM PN-21 packages are returned to the PM coordinator (PMC) by the last day of the assigned month.
The section head notes the reason for cancellation on the
" Preventive Maintenance PN-21 Performance Sheet," i.e.,
equipment not available, manpower not available.
The PMC then
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logs the cancellation of the activity.
Using engineering judgement and recommendations on the cancelled PM PN-21 packages, the PMC determines whether to manually reschedule the PM job for the next month or update the maintenance scheduling (MS) computer program to schedule for the next period.
This system appears to permit lower priority tasks to be completed with the resources that could be applied to overdue tasks of the same or higher priority.
Additional details on this issue are contained in Inspection Report 50-341/85026(DRS).
No items of noncompliance or deviations were identified in this area.
5.
Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period from May 1 to May 31, 1985.
The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified proper return to service of affected components.
Tours of the reactor building, turbine building, and RHR complex were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance.
During the inspection period while the reactor was in a maintenance outage, the inspectors verified that surveillance tests were conducted, containment integrity requirements were met, and amergency systems were available as necessary.
The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security plan.
The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls.
During the inspection, the inspectors walked down the accessible portions of the Standby Gas Treatment System and the Core Spray System to verify operability by comparing system lineup with plant drawings, as-built configuration or present valve lineup lists; observing equipment conditions that could degrade performance; and verified that instrumentation was properly valved, functioning, and calibrated.
These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedures.
No items of noncompliance or deviations were identified in this area.
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6.
. Monthly Maintenance Observation
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Station maintenance _ activities of safety-related. systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry.
codes or standards and in conformance with technical specifications.
The following items were considered during this review:
the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable;' quality control records.were maintained; activities _were accomplished by qualified personnel; parts and materials used were properly certified;-radiological controls were implemented; and, fire prevention controls were implemented.
.The following maintenance activities were observed / reviewed:
"0" Ring installation Reactor Vessel Head installation No items of noncompliance or deviations were identified in this area.
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Fire Protection
.The inspectors observed 57 fire rated doors throughout the plant to verify licensee action in resolving License Condition 9.e., which requires that prior to exceeding 5% power,- all early warning fire detectors shall be installed and all fire door assemblies shall be
' labeled or listed.by a nationally recognized testing laboratory.
The-inspectors additionally performed a more detailed examination of the corrective action by the licensee on a sample basis to determine if the programmatic requirements were being met.
Additional-details and findings on this inspection are contained in Inspection Report 50-341/85025(DRS).
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Independent Inspection - Operational-Readiness i
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The licensee continues to make progress in its preparations for initial
criticality'and power ascension. -Fire detector installation and fire door modifications appear to be the most significant critical path items.
Critical path items are continually reviewed by the licensee and the list.
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and schedules are revised to reflect actual conditions.
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~ Region III and licensee management met three times during the reporting period to review the status of licensee items affecting criticality,
. license conditions, and other items of mutual interest.
Senior Region III management attended the May 30, 1985, meeting and toured the facility with the inspectors prior-to the meeting.
The biweekly meetings will continue to be held until the~ issuance of the full power license.
No items of noncompliance or deviations were identified.
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9.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
Open items reviewed during the inspection are discussed in Paragraphs 2.a, 2.b and 2.c.
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Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph 4.b(2).
11.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) on May 31, 1985, and informally throughout the inspection period and summarized the scope and findings of the inspection activities.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any documents or processes as propriatary. The licansee acknowledged the findings of the inspection.
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