ML20128C178

Insp Rept 50-341/85-21 on 850407-30.Violation Noted:Failure to Implement Engineering Change Request Written to Delete Four & Add Two Test,Vent & Drain Caps

ML20128C178
Person / Time
Site:	Fermi
Issue date:	05/20/1985
From:	Chrissotimos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128C147	List: ML20128C144 ML20128C162 ML20128C178
References
50-341-85-21, NUDOCS 8505280212
Download: ML20128C178 (7)

See also: IR 05000341/1985021

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U. S. NUCLEAP. REGULATORY C0fEISSION

REGION III

Report No. 50-341/85021(DRP)

Docket No. 50-341 Operating License No. NPF-33

Licensee: Detroit Edison Company

-2000 Second Avenue

Detroit, MI 48226

Facility Name: Fermi 2

Inspection At: Fermi Site, Newport, MI

Inspection Conducted: April 7-30, 1985

Inspectors: -P. M. Byron

M. E. Parker

D. C. Jones

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Approved by: N.f..fr~issotimos, Chief 6-20 - 8 6

Projects Section 10 Date

Inspection Summary

Inspection on April 7-30, 1985 (Report No. 50-341/85021(DRP))

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Areas Inspected: Routine, unannounced inspection by resident inspectors

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of licensee action on previous inspector identified items; regional requests;

i independent inspections; preoperational test witnessing (recirculation system

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flow control test and containment isolation valve); operational safety

verification; monthly maintenance observation; monthly surveillance

observation; and surveillance--initial fueling. The inspection involved

a total of 283 inspector-hours onsite by three NRC inspectors, including

59 inspector-hours onsite during off-shifts.

Results: Of the eight areas inspected, no items of noncompliance or

deviations were identified in seven areas. Within the remaining area, one

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item of noncompliance was identified (Paragraph 2.b. - failure to follow

procedures).

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DETAILS

1. - Persons Contacted

• F. Agosti, Manager, Nuclear Operations

• L.-Bregni, Licensing Engineer

J. DuBay, Director, Planning and Control

0. Earle,_ Supervisor, Licensing

R. Eberhardt, Rad-Chem Engineer

• E. Griffing, Assistant Manager, Nuclear Operations

W. Holland, Vice-President, Fermi 2 Project

• W. Jens, Vice-President, Nuclear Operations

_S. Leach, Director, Nuclear Security

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'J. Leman, Maintenance Engineer

• L. Lessor, Assistant to the Superintendent

• R. Lenart, Superintendent, Nuclear Production

R. Mays, Director, Project Planning

• WJ Miller,-QA Supervisor, Operational Assurance

J. Nyquist, Assistant to Superintendent, Nuclear Production

• G. Overbeck, Assistant Plant Superintendent, Startup

J. Piana, Director, Nuclear Administration

. .J. Plona, Technical Engineer

'E. Preston, Operations Engineer

W. Ripley, Startup Director

C. P. Sexauer, Nuclear Production Administrator

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• 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 (341/84039-01(DRP)): Accessibility of valves for

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serviceability and manual operation of safety-related valves during

i abnormal conditions. This item identified numerous safety-related

, valves that would require mobile platforms to operate, inspect, and

L maintain the valves. The licensee is currently reviewing the

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accessibility of valves that require manual operation during

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emergency conditions and the ALARA considerations as recommended in

(- Regulatory Guide 8.8.

i Pending further review by the inspectors, this item remains open.

b. (Closed) Open Item (341/84053-03): This item has been determined to

be an item of noncompliance. On November 30 and December 1, 1984,

L., the inspectors noted that~one penetration test connection (T46-F009)

was not capped. Test connections must be administrative 1y

controlled to ensure their leak tightness or otherwise be subject

L to Type C testing. In response, the ifcensee issued an Engineering

L Design Package, EDP-1996, with the intent to:

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1) Identify those connections that required caps.

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2 Perform a production check to determine if caps are installed '

and if no cap is presently installed, install caps per the 1

guidelines of this EDP.

3) Update the drawings identified in this EDP to show caps where

required.  !

Although the EDP is to be followed as a procedure for installation and

verification of these caps, the Engineering Change Request, ECR-1996-2,

that was written to delete four and add two TVD caps, was not implemented

into the verification sheet resulting in the omission of vents E11-F091

and E41-F151. The inspector, by visual observation, found one of these

two vents (E41-F151) was uncapped. Also, upon review of POM Procedure

47.000.77, " Test, Vent, and Drain (TVD) Cap and Plug Verification," the

inspector found that penetration X-220 was omitted from the procedure's

verification sheet. This resulted in the absence of eight vents from

this procedure. This is considered an item of noncompliance

(341/85021-01(DRP)) with the requirements of 10 CFR 50, Appendix B,

Criterion V, in that there was inadequate implementation and review of

EDP-1996 and the accompanying Engineering Change Requests (ECR), which is

a failure to adhere to administrative procedures, specifically Plant

Operations Manual (POM) Procedure 12.000.64 "EDP Implementation

Procedure."

One item of noncompliance was identified.

3. Followup on Regional Requests

The inspectors were requested to review the licensee's program for

complying with licensed operator staffing as a result of recent problems

involving reactor operators at other facilities.

The inspectors reviewed the licensee's procedure POM 21.000.01, " Shift

Operations and Control Room," Revision 10, to determine if the licensee

was complying with 10 CFR 50.54(k) and 50.54(m) requirements concerning

licensed operator and senior operator staffing and shift manning. The

inspectors' review determined that the licensee's procedure does comply

with these requirements and that the licensee is currently implementing

these procedure requirements. The licensee is also meeting the

guidelines of Regulatory Guide 1.114, ' Guidance on Being Operator at the

Controls of a Nuclear Power Plant," and has provided a sketch in their

procedure clearly defining "at the controls." The inspectors have also

reviewed different aspects of operator staffing 'as a result of verifying

implementation of TMI requirements in the Safety Evaluation Report as

addressed in Inspection Report 50-341/85013(DRP).

No items of noncompliance or deviations were identified in this area. ,

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4.- Independent Inspections -' Operational Readiness

-The inspectors and Region III management met with licensee management

on' April 16, 1985, to review the licensee's readiness for issuance of

the full power license and the ' status of the license condition items.

The meetings will.be held biweekly until the issuance of the full power

license with the next meeting scheduled for May 3, 1985.

The inspectors continue to review the licensee's operational readiness

in preparation for the issuance of the full power license. The licensee's

ability to respond in a timely manner is perceived by the inspectors as

an area in which they need to devote additional effort. The inspectors

continue to observe vestiges of attitudes'which were prevalent during

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the construction phase. Various organizations work within their own

. sphere which results in minimized inter-organizational communication.

Each organization develops its own set of procedures, rules, and ways of

doing business. Individualistic approaches do not foster a sense of

teamwork. There has been a drastic improvement in this area but it has

been due primarily to the demobilization of various organizations and not

as a result of management attention.

The inspectors have observed that the Operations, Maintenance and

Modification groups all utilize PN-21's (work orders) yet have their

own data base, language, and cross referencing data. Reports generated

by each organization are not compatible with the needs of the others.

This is a contributor to the inter-organizational problems that the

inspectors have observed. The inspectors consider that the use of a

single data base would enhance communications between organizations.

. The licensee needs to take action to improve inter-organizational

communications. The inspectors consider that a solution to the

communication issue should result in a more cohesive organization

which.in turn will aid in the licensee's ability to respond to problems.

The inspectors have discussed their concerns with licensee management.

No items of noncompliance or deviations were identified in this area.

5. Preoperational Test hitnessing.

The inspectors reviewed portions of preoperational test procedures,

reviewed procedure results completed to date, toured the areas containing

system equipment, intervi+wed personnel, and observed test activities of

those preoperational tests identified below.

During this review, the inspectors noted that the latest revision of the

test procedure was available and in use by crew members, the minimum crew

requirements were met, the test prerequisites were met, appropriate plant

systems were in service, the special test equipment required by the

procedure was calibrated and in service, the test was performed as

required by approved procedures, temporary modifications _ such as jumpers

.were installed and tracked per established administrative controls, and

test results for the tests observed by the inspectors indicated that

acceptance criteria were met.

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a. Recirculation System Flow Control Test

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The inspectors observed the performance of portions of

Preoperational-Test PRET B3100.001, Revision 2, " Reactor

Recirculation System": Initial Pump Operation Test and Two-Pump

Operation.

b. Containment Isolation Valve

The' inspectors observed the performance of portions of

Preoperational Test PRET T4804.000, Revision 2, " Thermal Recombiner

System": Division-I Logic Verification and Division II Logic

Verification.

No items of noncompliance or deviations were identified in this area.

6. Operational Safety Verification

l The inspectors observed control room operations, reviewed applicable logs-

and conducted discussions with control room operators during the period

! from April 7 to April 30, 1985. The inspectors verified the operability

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of selected emergency systems, reviewed tagout records, and verified

' proper' return to service of affected components. Tours of the reactor

L 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

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had:been. initiated for equipment in need of' maintenance.

i; During'the inspection period while the' reactor was in a maintenance

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outage,:the inspectors verified that-surveillance tests were conducted, .

secondary containment integrity requirements were met, and emergency

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

t verified implementation of radiation protection controls. During the

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inspection, the inspectors walked down the accessible portions of the

Core Spray System and the Low Press'ure Coolant Injection 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.

The inspectors reviewed new procedures and changes to procedures that

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were implemented during the inspection period.~ The review consisted of a

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verification for accuracy, correctness, and compliance with regulatory

requirements.

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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.

No11tems of noncompliance or deviations were identified in this area.

- 7. Monthly Maintenance Observation

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Station maintenance activities of safety related systems and components

listed below were observed 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; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by

qualified personnel; parts and materials used were properly certified;

radiological controls were implemented; and, fire prevention controls

were implemented. Work requests were reviewed to determine status of

outstanding jobs-and to assure that' priority is assigned to safety-

related equipment maintenance which may affect system performance.

The following' maintenance activities were observed / reviewed:

24/48 VDC Battery Replacement

. Removal / Installation of Control Rod Drives

Control Rod Drive Rebuild

Position Indicator Probe Changeout

No items of noncompliance or deviations were observed in this area.

8. Monthly Surveillance Observation

i:- The inspectors observed surveillance testing required by technical

specifications and verified that: testing was performed in accordance

with adequate procedures; test instrumentation was calibrated; limiting

conditions for operation were met; removal and restoration of the

affected components were accomplished; test results conformed with

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. technical specifications and procedure requirements and were reviewed by

personnel ~other than the individual directing the test; and any

deficiencies identified during the testing were properly reviewed and

resolved by appropriate management personnel.

l' The inspectors witnessed portions of the following test activities:

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Pre and Post CRD Removal Verification

Division I/ Division II 130 VDC Battery Charger Calibration

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No items of noncompliance or deviations were identified in this area.

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9. Surveillance - Initial Fueling

The. inspectors observed the following surveillance testing conducted

during initial fueling to verify that: the tests were accomplished in

accordance with properly approved procedures; the procedures used were

consistent with regulatory requirements, licensee commitments, ard

administrative controls; minimum crew requirements were met; test

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prerequisites were completed, special test equipment was calibrated and

- in service, and required data was recorded for final review and analysis;

the qualifications of personnel conducting the test were adequate; and

the test results were adequate.

' Shutdown Margin Demonstration

Control Rod Drive Friction Testing

Control Rod Drive Timing Tests

No items of noncompliance or deviations were identified in this area.

10. 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 ifcensee or both. Open items reviewed during

. the inspection are discussed in Paragraph 2.

11. Exit Interview

The inspectors met with. licensee representatives (denoted in Paragraph 1)

on April 29, 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 such

documents / processes as proprietary. The licensee acknowledged the

findings of the inspection.

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