ML20149K869

Insp Rept 50-341/97-03 on 970320-0509.Violations Noted.Major Areas Inspected:Operations,Engineering,Maint & Plant Plant Support

ML20149K869
Person / Time
Site:	Fermi
Issue date:	07/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149K861	List: ML20149K859 ML20149K865 ML20149K869
References
50-341-97-03, 50-341-97-3, NUDOCS 9707300203
Download: ML20149K869 (42)

See also: IR 05000341/1997003

Text

e

,

U.S. NUCLEAR REGULATORY COMMISSION

i

'

l REG lON 3

!

,

Docket No

50-341

License No: NPF-43

.

Report No: 50-341/97003

]

i Licensee: Detroit Edison Company (DECO)

1

)

Facility: Enrico Fermi, Unit 2

4

,

Location: 6400 N. Dixie Hwy.

Newport, MI 48166

i

Dates: March 20 through May 9,1997

Inspectors: G. Harris, Senior Resident inspector

C. O'Keefe, Resident inspector

I A. Walker, Reactor inspector

A. Dunlop, Reactor Inspector

S. DuPont, Project Engineer

D. McNeil, Operator Licensing Examiner

S. Stasek, Senior Resident inspector,

Davis-Besse

D. Butler, Reactor Inspector

Approved by: Michael J. Jordan, Chief

Reactor Projects Branch 5

l

'

.

I

~

9707300203 970701

PDR ADOCK 05000341

G PDR

.- . .- .. -- .- -. .. - - - . - . . - . . - . - . - - - - -

.

.

'

EXECUTIVE SUMMARY

Enrico Fermi, Unit 2

,

NRC Inspection Report 50-341/97003

,

This inspection included aspects of licensee operations, engineering, maintenance, and l

plant support. The report covers a 7-week period of resident inspection.

Ooerations

• The inspector concluded that plant restart was performed in a coordinated and

t

controlled manner. Equipment problems were adequately resolved using

i appropriate support personnel. Management oversight was effective in resolving

i problems, allowing the operating shift to operate the plant with minimum

distractions. Each problem was resolved in a methodical and conservative manner

before resuming startup. Operator performance was focussed and error-free.

(01.1)

e The inspectors identified that a reactor building ventilation isolation (ESF actuation)

was caused by a lack of attention to detailin review of an electrical print. (01.2)

• The inspectors concluded that current administrative controls for the backseating of

valves were weak in tthat they did not specify controls and necessary evaluations

prior to backseating motor operated valves. (01.3)

• The inspectors concluded that the licensee's drywell cleanup and closecut activities  !

were largely effective based on drywell cleanliness and equipment condition. I

(O2.3) i

Maintenance I

l

• The licensee identified that two failures of the Reactor Core Isolation Cooling

inboard Steamline Isolation Valve (E5150-F007) were caused by maintenance

workers. The inspectors identified that the second failure was initially not detected

and the system was unknowingly returned to service in an abnormal lineup. The

inspectors concluded that these problems were indicative of lack of attention to

detail and lack of sensitivity to potential equipment damage by station personnel,

lack of questioning attitude by operators during the surveillances and subsequent

system restoration, and procedures that were inadequate to ensure the system was

tested and restored to a proper lineup following testing. A violation was issued.

(M1.4)

• The licensee identified numerous examples of lack of attention to detail during

performance of maintenance work. These resulted in restoring equipment to

1

2 .

1

. ..- - . - - --- .- . _ _ - _ - - - _ . . ._.

.

-

i service without fuses, unrecognized damage, and rework. The inspectors

concluded that these examples were indicative of an adverse trend in personnel

performance during the conduct of maintenance. (M1.4, M1.6)

l

• The inspectors identified an apparent violation pertaining to the failure to recognize

i the significance of the problem with hardening grease associated with the MCC

fused disconnect switches and take prompt actions to prevent recurrence.

(M 2.1.1 )

• The inspectors identified an apparent violation pertaining to the lack of establishing

preventive maintenance (PM) activities for the MCC fused disconnect switches.

The licensee narrowly interpreted the requirement for PM activities to not include

devises such as the disconnect switches. (M2.1.2)

• Tne inspectors identified an apparent violation for failure to implement corrective

actions in a timely manner for a 1988 industry problem with motor operated valve

(MOV) actuators. Following failure of the High Pressure Coolant Injection Valve

actuator, the licensee inspected 67 safety related and important to safety MOV

actuators because this problem involved a potential common mode failure

mechanism. The population inspected was large because poor maintenance

documentation prevented the licenses from determining which actuators had

corrective actions completed in the past. (M2.2)

• The inspectors identified a violation concerning inadequate work instructions and

procedures to ensure new battery cells were fully charged and installed in a

condition to support the function of the Division 124/48 Volt Battery. (M2.3)

e The inspectors identified a violation for inadequate work instructions that led to an

emergency diesel generator starting air compressor being left in the OFF position.

Weak configuration control practices during work activities contributed to this <

event, which unnecessarily challenged the operability of the associated engine.

(M3.1)

e The inspectors concluded that the On-Site Review Organization was initially slow in

resolving issues associated with MCC fused disconnect switches. Corrective l

actions were implemented on a substantial portion of the affected population before

the adequacy of the corrective actions were adequately assessed. (M7.1)

l

Enaineerina l

I

e The licensee identified and corrected several Emergency Equipment Cooling Water l

(EECW) System design deficiencies. These included lack of redundant power for

containment isolation valves, susceptibility to high energy line breaks inside primary

containment, and an interlock with Reactor Building Closed Cooling Water System

isolation valves which could have prevented initiating EECW during remote

shutdown conditions. The inspectors concluded that the licensee appeared to have

adequately addressed these issues prior to plant restart. (E2.1)

l

3

l

l

1

_ _ _ _ _ _ _ _ _ _ . .-. __ _ _ _ _

i

l-

l

i.

! Plant Sucoort

• The inspectors identified a violation of radiological requirements concerning workers

-

that did not follow procedures and notify Radiological Protection personnel before

accessing a work area greater than 8 feet above the floor. This resulted in the

! workers not receiving a briefing on radiological conditions in the entire work area.

(R1.2)

i

4

>

,

W

9

< <

!

i

1

! I

J

)

1

,

,

I

4

_ _ - - -. . - . . - . - --_ _- _ _ .- . . _ . . -- - _ _ _ _ _ _ _ _ - - _ . --

1

,

! Honort Details

l

Summarv of Plant Status

i

Unit 2 began this inspection period in a forced outage to repair the main generator. During

the outage, Motor Operated Valve (MOV) inspections and Motor Control Center (MCC)

fused disconnect switch inspections and lubrication were conducted on a significant

'

number of pieces of equipment. Also during this outage, engineering identified and

corrected several Emergency Equipment Cooling Water (EECW) System design issues

through system modifications. The plant was restarted on May 2 and the main generator

was synchronized to the grid on May 6.

,

l. Operations

01 Conduct of Operations

01.1 General Comments and Startuo Observations (717071

a. Insoection Scope (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of

plant operations. Specific events and noteworthy observations are detailed in the

sections below.

Fermi 2 unit was restarted on May 2. The inspectors observed activities in the

control room and in the plant associated with starting up the plant. This included

reactor startup, Reactor Core Isolation Coolant (RCIC) and High Pressure Coolant

injection System (HPCI) surveillance testing, turbine roll and segments of power  !

ascension. Inspectors reviewed design basis documents and other design data and  !

discussed several equipment problems with engineering to assess equipment

operability and the adequacy of licensee response,

b. Findinas and Observations.

The licensee consequently delayed startup about one day while repairs were made

to a controller for the Combustion Turbine Generator 11-1. Startup was further )

delayed when post-modification testing of the RCIC steam admission valve (E5150- i

F045) indicated that the valve opened faster than the acceptance criteria. Actual l

speed was analyzed for existing bus voltage and found to be acceptable.

Control room operations during the startup were observed to be conducted in a

professional and controlled manner. Reactivity manipulations were particularly well

controlled. The inspectors observed good communications and coordination

between Operations personnel and maintenance and engineering personnel. Station

management oversight of critical startup activities was effective in coordinating

efforts between operations and other departments. This coordination increased the

availability of the control room supervisor to manage activities within the control

room. The inspectors observed that briefings were frequently held and were l

5

I

.

l

~

1

l

.

sufficiently detailed. Operations worked effectively with Reactor Engineering to l

resolve an operator concern that two control rods had higher than average notch i

'

worth near the expected critical position.

c. Conclusions

The inspector concluded that plant restart was performed in a coordinated and

controlled manner. Equipment problems were adequately resolved using l'

appropriate support personnel. Management oversight was closely involved in

resolving problems, allowing the operating shift to operate the plant with minimum

distractions. Each problem was resolved in a methodical and conservative manner

before resuming startup. Operator performance was focussed and error-free.

01.2 Reactor Buildina Ventilation (RBHVAC) Trio with Resultina Momentary Loss of

Secondarv Containment

a. Insoection Scone (93702)

The inspectors conducted an event followup and independent assessment of the

circumstances surrounding the loss of secondary containment. The licensee's

cause determination and corrective actions were reviewed for adequacy.

Secondary containment integrity during the event was evaluated by reviewing

operator logs, annunciator response procedures, and technical specifications. The ,

event and corrective actions were discussed with plant management. l

l

b. Observations and Findinas i

1

' On March 25, RBHVAC System alarms were received for Reactor Building High j

Pressure. Control room operators identified that the West RBHVAC Exhaust Fan

Damper (T41-F014) failed shut. This resulted in a positive pressure in the reactor

building for about 2 minutes before a normal ventilation lineup and building pressure I

could be restored. The maximum recorded reactor building pressure during the

event was +0.5 inches of water. The licensee reported this event in accordance 4

with 10 CFR 50.72 because the TS for secondary containment required that the

Reactor Building be maintained at greater than or equal to 0.125 inches of water  ;

vacuum.

While response time testing (see E2.2 below) was being performed, the solenoid

operated valve (T41-F056) that controls air to damper (T41-F014) began to leak

sufficient air that the force of the actuator spring shut the damper. The inspectors

determined that a low flow trip of the fans associated with the failed damper did

not occur because the logic was not satisfied by an exhaust fan operating under j

shutoff conditions. As a result, the supply of air into the reactor building exceeded ;

the exhaust flow, causing a pressure increase.

Upon recognition of the equipment problem, control room operators tripped the l

affected supply and exhaust fans and started the idle set of fans to restore the  !

I

1

l

l

_ _ _ _ _ _ _ - _ _ _ _ _ - .

.

.

reactor building to a negative pressure. The licensee then replaced the failed

soleno;d operated valve (T41-F056).

Corrective actions included sending the failed valve offsite for failure analysis and

performing a system review to determine whether the no-flow trip should have

prevented this event. Preventive maintenance for this type of valve was also under

review.

c. Conclusions

The failure of T41-F056 resulted in a brief loss of secondary containment and a

violation of TS 3.5.2, Action b. The safety significance of this event was negligible

,

because RBHVAC effluent monitoring was maintained, and no release of radioactive

material occurred during this brief event. The licensee is reviewing the design

adequacy which will be documented in Licensee Event Report (LER) 97-07.

01.3 Backseatina of MOVs

'

a. Insoection Scooe (92901)

The inspectors reviewed administrative and valve lineup procedures. The ,

inspectors held discussions with operations and station management. I

i

b. Findina and Observationg l

l

While reviewing the startup schedule, the inspector noted, as was done during the

previous cycle, that the reactor recirculation pump isolation valves were backseated

to reduce potential packing leakage. The discharge valves are closed during low

pressure coolant injection.

l

'

The inspector was concerned that although an engineering evaluation had been

conducted, the valves were being placed in a position other than that described in

the current valve lineup procadures for an extended period while operating at

power. The inspector noted that the current operations procedures (MOP 03,

" Operations Policies and Practices") lacked formal controls and management

expectations concerning the backseating of valves, such as specifying the hanging

of caution tags for a configuration different than that specified by the current

system operating procedure (SOP) lineup. Operations management agreed to

review their administrative controls to ensure better control of backseating motor

operated valves.

7

- . -- .. _ - . . - . -- -.-.-.-... - --.- . .- _ ..

l

i

j.

c. Conclusions

The inspector concluded that current administrative controls for the backseating of I

l valves were weak. Procedures did not specify controls and evaluations necessary

l prior to backseating motor operated valves. )

1

02 Operational Status of Facilities and Equipment

O 2.1 Enaineered Safetv Feature System Walkdowns (71707)

The inspectors used inspection Procedure 71707 to walk down accessible portions

) of the following ESF systems. The inspectors observed the condition of the

j equipment, visually verified that the systems were in the required lineup, and l

confirmed that system instrementation indicated values appropriate to the plant I

1

l conditions.  ;

J l

i

e Division 2 Non-interruotible Air Supply System

o High Pressure Coolant injection System (HPCI)

e Reactor Core Isolation Cooling System (RCIC)  !

i e Division 2 Core Spray System )

I e Containment Vacuum Breakers i

'

l e Division 1 and 2 24/48V Batteries

e Division 1 and 2 EECW

] e Division 1 Residual Heat Removal System (RHR)

3

,

'

i

j Equipment operability, material r,ondition, system lineups, instrument indications, 1

!

and housekeeping were acceptable in all cases. Several minor discrepancies were l

i brought to the licensee's attention, including:

• A spring can support for Core Spray System above the torus appeared to be l

} loaded more heavily than it should have been, based on hot and cold load 1

markings. Engineering produced a construction-era analysis which showed  ;

,

the current load was acceptable, but the markings had not been changed. )

i

! * The A RHR pump motor had a very small oilleak from the lower motor

'

reservoir.

I e Safety relief valve J vacuum breaker had a small quantity of foreign material

inside the protective screen. (See 02.4)

The foreign material was promptly removed from the vacuum brea~ker assembly,

! and work requests were written for the oil leak.

I

!

i

i

! 8

l

i

'

1

i

!

-

. - , - - - . - . ,

_ _ - - _ .

._ _ _ _ _ _ _ _ _ _ _ _ - _ . __

.

.

02.2 Licensee Reoorted Potential Habitability Issue with Dedicated Shutdown Procedure

a. Insoection Scone (92700)

The inspectors conducted an independent reviewed of the licensee's report that the

Dedicated Shutdown procedure did not account for potential habitability problems

during a specific fire scenario. The inspectors interviewed engineering personnel

and conducted field walkdowns of the Dedicated Shutdown procedure.

b. Observations and Findinas

The licensee determined during review of the Dedicated Shutdown Procedure

(20.000.18) that certain fire and carbon dioxide system dampers may not close or

would reopen during a fire requiring the use of the Dedicated Shutdown Procedure.

The dampers could open with loss of Division 2 AC power and the loss of control

air. The open dampers could create a hazardous atmosphere in a room which is

adjacent to the Division 2 battery room and required for entry while performing

20.00.18. This was reported to the NRC Operations Center in accordance with the

operating license on April 11.

The licensee corrective action was to place Self Contained Breathing Apparatus in )

,

the Radwaste Building Switchgear Room to be used if required during a Dedicated i

l

'

Shutdown.

c. Conclusion

l

The inspectors concluded that the licensee corrective action for this issue was

acceptable.

02.3 Insoectors identifv Drvwgli Eauioment Discrenancies

_

a. Insoection Scoce (71707)

On April 24, the inspectors conducted a walkdown of the drywell to observe the

cleanliness and equipment condition after the licensee had conducted a drywell

closeout inspection. j

b. Observations and Findinas i

l

The inspectors noted that the general condition of the drywell was very good, with l

'

no debris from outage work.

The inspectors identified a small quantity of an orange substance on the inside of

the protective screen covering the "J" safety relief valve vacuum breaker. Because

of the valve orientation, the inspectors were concerned that the substance might

drop inside the vacuum breaker and prevent reseating following valve actuation.

The licensee was notified, and the substance was promptly removed from the

9

._

.

.

valve. It was subsequently identified to be room temperature vulcanizer (RTV)

material, although the source could not be identified.

The inspectors also identified a small oil leak coming from the "A" Reactor

Recirculation Pump motor upper thrust bearing resistance temperature detector.

The pump was not running at the time. The inspectors reported this oil leak to the

Nuclear Shift Supervisor (NSS). Deviation Event Report 97-0647 was initiated to

evaluate the leak.

On April 25, the system engineer and maintenance personnel inspected the leak and

found that the oil had seeped down into an electrical terminal box, and potentially

down into conduits exiting the bottom of the terminal box. The terminal box was

found to contain considerable debris in addition to standing oil. The licensee

believed the terminal box had not been opened since construction. The debris was

removed and the oil was wiped up.

System engineering subsequently performed an evaluation which stated that the oil

leakage was acceptably small to defer repair until a future outage, when parts could

be obtained. The oil leak was presumed to have existed for a long time, on the

order of years, due to the amount of oil present on the outside of the motor. The

pump was determined to be operable. Because the insulation on wiring inside the

affected terminal box was all oil-resistant, no additional electrical checks were

performed. The inspectors discussed the assessment with senior licensee

management and the electrical maintenance engineer, who agreed with the system

engineering assessment.

c. Conclusions

The inspectors were concerned that the operability determination for the "A"

Reactor Recirculation Pump was based on analysis, when electrical checks could

have been performed while the pump was accessible to confirm the analysis. The

inspectors agreed that the leak rate was small and were satisfied that the "A"

Reactor Recirculation Pump remained operable due to the small size of the leak and

the non-critical location on the motor. Each of the conductors exposed to the oil

leaking out was oil-resistant and performed only indication functions. The inspector

determined by reviewing drawings, that the leak was above the minimum

acceptable oillevel for the bearing and did not affect operability. The inspectors

concluded that the licensee's drywell cleanup and closeout activities were effective

based on the cleanliness and equipment condition.

08 Miscellaneous Operations issues (92902)

08.1 (Ocen) Unresolved item 50-341/96016-07: Condensate Storage Tank Freeze

Protection. The inspectors reviewed control room logs, conducted interviews and

reviewed design basis documentation associated with freezing of sense lines for

condensate stora0e tank level indication on January 17,1997.

10

.

. ._

.. . - _. -

.

.

While conducting routine control board monitoring, operators noted that control

room CST levelinstrumentation was off scale high. Further investigation by the

licensee and inspectors revealed that the door to the CST instrument panel, located

outside the plant, had been bent open to obtain surveillance readings because the

cabinet lock had frozen. The inspectors reviewed control room logs and determined

that the operators declared CST levelinstrumentation inoperable and took what

was believed to be the correct actions in accordance with TS 3.3.3.

.

The inspectors reviewed design basis documentation that stated that CST

instrumentation provide signals to initiate automatic suction path swapover to the ,

'

torus for the HPCI and RCIC systems on a low CST level condition. In addition,

annunciators that provide signals to alert control room operators of the need to

perform manual realignment on low level may not be available when the instrument

freezes because this causes transmitter output to indicate offscale high. The

inspector was concerned that degradation of these features could complicate the

i response to an accident.

. The inspectors noted that a similar freeze related event had occurred in 1992.

During that event, the inspector noted that control room operators declared standby  ;

feedwater systam inoperable and immediately took actions to align HPCI and RCIC l

to the torus. In the January 1997 event the inspector noted that the licensee l

declared the CST low level actuation feature inoperable and began to take actions l

to restore the instrumentation within operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In one case,

the licensee took prompt action while during the second event, the licensee used

i the TS Limiting Condition of Operation allowed time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the

instrumentation. The inspector was concerned with the difference in the licensee's

actions to address similar problems.

l

. The inspector reviewed the applicable TS and held subsequent discussions with

- Operations management concerning the differences in the implementation of the

i TS actions. The inspector did not complete the inspection and this item will remain

i

open pending inspector's review of the licensee's corrective actions.

fl. Maintenance

,

M1 Conduct of Maintenance  ;

,

M 1.1 General Comments

.

a. Insoection Scoce (62703)

The inspectors observed all or portions of the following surveillance and work

activities:

e Division 124/48V Battery Cell Replacement

e Calibration of Division 1 EECW Pump Discharge Pressure Transmitter

e General Service Water (GSW) Intake Dredging

11

.

.

• Sequence of Events Testing for Destaged GSW Pumps

• Power Supply Modification to P44-F607A and F607B

e MCC Fused Disconnect Switch Lubrication and Disassembly

e Computer Room Chiller Maintenance Activities

e Post Accident Sampling Surveillance

e Reactor Building-Torus Vacuum Breaker Operability Surveillance

e Reactor Flow Unit Functional Check

e HPCI Auxiliary Oil Pump Troubleshooting Maintenance Activities

e Recharging Hydraulic Control Unit Weekly Surveillance

e Reactor instrumentation Reference Leg Backfill Functional Surveillance

e Drywell Cooling Modification Work

b. Observations and Findinas

Maintenance workers and supervisors indicated that work packages had been

getting to the shops at least a week in advance of the scheduled work date, thus

allowing better walkdowns and work preparation. The resulting familiarity of work

scope and system configuration allowed for better pre-job briefs. The inspectors

observed these improvements during several briefs.

The inspector observed portions of the Reactor Protection System response time

testing, noting the testing procedure required the use of a strip chart recorder

capable of recording data at both 4 inches per second and 40 inches per second.

However, the recorder used by the technicians was calibrated in metric units. The

inspectors determined that the use of the different strip chart recorder did not have

a significant impact on the accuracy of the results of the response time testing.

However, the inspector was concerned that the technicians failed to fully execute a

procedure change or question procedure compliance given this discrepancy with

written requirements. The inspector discussed the observation with Maintenance

and plant management, and determined that licensee management expectations

were that the correct scale should have been used or the procedure changed to

permit using an equivalent device. The procedure was revised.

M1.?. Foreian Material Exclusion (FME) Proaram Weakness

a. Insoection Scoce (62703)

The inspectors observed work performed on Control Center Heating, Ventilation and

Air Conditioning System (CCHVAC), including the disassembly of an air actuated

damper for the emergency equipment room cooling system. The inspector also

conducted walkdowns of plant equipment including the diesel generators. The

inspectors reviewed associated DERs and conducted interviews with appropriate

site personnel.

b. Findinas and Observations

The inspectors observed the workers performing preventive maintenance activities

on the equipment room cooling ventilation damper, including the disassembly and

12

__

.

.

reassembly of the CCHVAC mechanical equipment room cooling ventilation damper,

and removal of air lines for the assembly.

The inspectors noted the workers did not tape the ends of several pieces of

instrument tubing to preclude the entry of foreign material. In addition, the workers

left the immediate area on at least two occasions, leaving the tubing unprotected.

Common industry practice, the inspector noted, was to tape ends of open tubing

when control of the tubing has been not ensured.

In addition, the inspectors discovered during walkdowns that dust covers were

missing from EDG air receiver gauge test fittings. The dust covers are intended to

prevent entry of foreign material that could impact instrument performance.

Further, the inspectors learned that station personnel had observed the dust covers

to be removed at least a month earlier but had not corrected the problem. The

licensee determined that the covers were not required for operability of the EDGs.

Additionally, the licensee determined that the EDGs were never rended inoperable

because of FME in the test gage test fittings.

The inspectors reviewed a recent DER that stated that the licensee continues to

identify potential weaknesses in the FME program. For example, the drywell had

been closed out even with some materials not documented as being removed from

the drywell. The inspector confirmed that some accountability sheets did not

document that items were removed from the drywell.

In inspection Report 50-341/97002, the inspectors noted that maintenance workers

failed to properly install FME barriers during activities associated with the high

pressure coolant injection valve. As a result of these and other findings in foreign i

material exclusion, the licensee initiated a review of its FME program against l

industry standards. l

c. Conclusions

The inspectors concluded that weaknesses existed in the stations foreign material

exclusion program, and were concerned that current practices in this area could

potentially impact safety related equipment. The inspectors will evaluate the

results of the 1.censee's FME program review and FME practices as an Inspection

Followup Item. (IFI)(50-341/97003-01)

M1.3 Work Performed on the Wrona Eauioment due to Lack of Self-Checkina

a. Insoection Scooe (92903)

The inspectors performed an independent review of the circumstances surrounding

the licensee's identification of the adjustment of the wrong circuit card during

calibration work and leak repairs made on an incorrect level switch. The licensee's

root cause evaluation and corrective actions were reviewed for adequacy. The

event and corrective actions were discussed with appropriate maintenance

supervisors. The inspector reviewed work packages and conducted interviews with

13

.

O

Maintenance personnel. The inspectors performed walkdowns of affected

components.

b. Findinas and Observation

b.1 Mechanical maintenance personnel were assigned to perform repairs to a leak on

the barometric condenser level switch to support calibration activities. The

inspector walked down the RCIC system and noted both high and low level

switches located near each other. The inspector interviewed personnel and learned

that mechanical maintenance personnel attempted to stop the leak by adding

packing on two previous occasions. After all attempts were unsuccessful, the

licensee identified that the leak repair efforts were performed on the wrong level

switch.

The inspector reviewed the work package and noted that the work had been

treated as on emergent work item and was not walked down prior to starting the

work. Interviews with mechanical maintenance personnel revealed that the work

on the wrong level switch occurred as a result of inadequate use of self checking

and verification techniques prior to starting the work on the two occasions.

The inspector verified that the inappropriate work activities did not permanently

damage the component. The inspector verified that the correct level switch was

repaired and the calibration performed as required.

b.2 On April 2, I&C technicians performing a calibration on computer monitoring inputs I

for the general plant monitoring computer per procedure 44.030.255 inadvertently

adjusted the wrong card. The technicians discovered their error immediately when

the expected system response was not observed during an adjustment. Work was

stopped and the control room informed. The two cards involved were subsequently

re-calibrated.

The licensee concluded the event was a result of inadequate use of self-check. The

inspectors discussed the event with l&C supervision and examined the panel and

noted that the cards involved were in close proximity to each other (less than

1 inch apart), and had a similar appearance. The licensee was considering using

self-adhesive tags to mark components being worked in such situations. The

significance of the error was minimal, as it involved inputs to a monitoring

computer which was not required for plant operation.

DER 97-0501 was written to document the event and track corrective actions,

c. Conclusion

The inspectors concluded that these events were caused by lack of self checking.

The safety significance of each issue was minor. However, the inspectors were

concerned by the lack of attention to detail during work.

14

_ _ __

.

.

M1.4 Failures of RCIC inboard Steamline Isolation Valve Caused by inadeauste

Procedures and Station Personnel Errors

a. Insoection Scoce (92903)

The inspectors conducted an independent review of the circumstances of the a

failure of the RCIC valve after corrective maintenance. Work packages for all work

on the valve during the outage were reviewed. The surveillance history was also

reviewed. The as found condition of the valve was discussed with maintenance

engineers, and the surveillance logic testing was discussed with the system

engineer. Scheduling and assignment of post-maintenance testing (PMT) was

discussed with the Work Planning Supervisor and personnel in the Surveillance

Group,

b. Observations and Findinas

The RCIC Inboard Steamline isolation Valve (E5150f007) failed to open on demand

during a surveillance run as PMT for motor pinion gear work. Following corrective

maintenance, the valve was tested and retumed to service, but was then found to

be open with an isolation signal present.

On April 17, a control room operator identified that E5150-F007 was open but

should have been closed; the valve logic had a valid isolation signal present for low

steam line pressure because the plant was in cold shutdown. The valve had been

opened two shifts earlier during performance of surveillance 44.060.001.

DER 97-0600 was written to document the issue and track corrective agtions.

Maintenance conducted troubleshooting under Work Request (WR) 000Z974252,

which identified that the 7-strand wire used to transmit automatic isolation signals

had broken conductors at a lug connection inside the limit switch cover of the

l actuator. Yhe limit switch cover had been removed twice during the outage for

maintenance activities. Maintenance concluded that the wire was inadvertently 1

damaged during one of those maintenance activities. The inspectors reviewed the  !

'

PMTs on the valve worked during the current outage and confirmed that they did

not test the automatic isolation function. Maintenance engineers stated that

current PMT philosophy was to test only those portions of the circuit which were

within the work scope (i.e., were known to be disturbed). The removal of the limit

switch cover was not recognized as part of the work scope. Thus the valve was l

not tested for potential damage to the 7-wire cable. The valve was only tested for  !

the remote manual operation function.

The licensee had identified that this type of conductor in MOV actuators was i

susceptible to damage during a similar problem in 1993, as documented in I

DER 93-0013. The inspectors determined that maintenance work practices had not

been changed to minimize the possibility of damage, nor was testing changed to

verify that no damage was caused during work inside the limit switch compartment i

as a result of that event. A caution was added to the MOV maintenance procedure

'

to alert workers of the potential for damage. At the conclusion of this inspection,

15

l

_ _

l

~

\

!

.

maintenance was re-evaluating the method used to determine the scope of PMT for

MOV work to include a verification of electrical continuity to the maximum practical

extent, rather than limiting testing to just check components within the work

scope.

1

The inspectors reviewed the work and surveillance history for the RCIC system, and

found that 44.060.001 had been partially performed on April 10 as PMT for valve

work, and again partially performed on April 17 following troubleshooting of

E5150 F007. The inspectors reviewed surveillance 44.060.001, and WRs

000Z974252 and 000Z974210 and identified the following deficiencies:

e Both partial surveillances performed steps which opened E5150-F007, but

no steps were performed to shut or verify it shut.

e 44.060.001 did not require verifying the position of E5150-F007 at the

conclusion of the surveillance,

o The steps performed as partial surveillance for PMTs on these WRs did not

cause the valve to be shut intentionally, and operator logs indicated no

verification of RCIC system lineup was performed at the conclusion of these

partial surveillances.

The inspectors discussed the surveillance with the system engineer, and determined

that E5150 F007 should have automatically shut when the jumper was removed

that disabled the low steam pressure isolation. However, operators and l&C

personnel performing the surveillance failed to recognize and verify that the valve

did not shut as expected.

c. Conclusions

The failure was not detected during post maintenance testing of the valve, resulting ,

in returning the system to service in an abnormal lineup. The inspectors concluded l

that this problem was indicative of lack of attention to detail, lack of questioning (

attitude by operators during the surveillances and system restoration, and

procedures that were inadequate to ensure the system was restored to a proper

lineup following testing. These problems are significant because E5150-F007 was

a safety related valve in an ESF system; this normally inaccessible valve had a

I

primary containment isolation function which was not functional. The significance

was somewhat mitigated because the plant was in cold shutdown at the time, so

the RCIC injection function and the containment isolation function were not I

required. The failure was identified by the licensee. 1

The inspectors consic'ered that Maintenance corrective actions for previous failures

of small wires inside MOVs were weak in that actions were not taken to verify that I

such wires were functionally checked during work which could have damaged

them.

l

l

l

16

_ _ _ _ _ _ _ _ _

_ _ _ . -- . _ _ __ _

,

.

i-

The inspectors concluded that surveillance procedure 44.060.001, and work

'

request 000Z974252 were inadequate to the circumstances. Specifically,

44.060.01 failed to require a verification that the RCIC system was restored upon

completion of testing, and WR 000Z974252 failed to specify a PMT that

functionally tested the repaired conductor. This was considered a violation of

'

10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings."

(VIO)(50-341/97003-02)

The inspectors were concerned by the licensee's practice of performing partial

surveillances by specifying selected non-sequential steps. The inspectors will

review this issue in order to assess the conformance to 10 CFR 50.59 safety

evaluation process. This will be tracked as an Unresolved Item pending further NRC

i inspections into the administrative controls rad actual practices of specifying

selected, non-sequential steps from a surveillance procedure for testing.

(URI)(50-341/97003-03)

M1.6 Conclusions on Conduct of Maintenance

The inspectors noted that equipment performance was very good at the end of this

inspection period. Plant startup went well, with few equipment problems.

4 Maintenance support during startup testing and in responding to equipment

problems was very good, and Outage Management and Operations Support

personnel helped coordinate startup testing.

'

However, this report documents a significant number of errors and problems during

,

the conduct of maintenance activities during this inspection period. The inspectors

'

noted that the licensee identified a number of maintenance related problems and

took prompt corrective actions. These issues included:

l e The Division 2 Torus Spray Valve (E1150-F027A) failed to open on demand

during a surveillance because an electrical terminal was not adequately

tightened. The valve actuator had been worked and successfully passed its

PMT two days previously. (DER 97-0467)

e The Division 2 RBCCW Supply isolation Valve (P44-F603B) failed to stroke

due to a limit switch damaged during maintenance activities. (DER 97-0662)

e Reactor water chemistry conductivity monitor P33-R500 indicated erratically

because two wires were reversed during restoration. (DER 97-0684)

e GSW pump #3 required several pump packing adjustments and eventual

replacement. (DERs 97-0420, 97-0670)

e The Division 1 EECW Drywell Return Outboard Isolation Valve (P44-F607A)

had wiring errors made during modification work that caused blown fuses

and damaged the control transformer. (DER 97-0623)

17

,

- _ _ . _ - . . .

.

..

1

e The East Stator Water Cooling Pump Breaker Closing Spring Charging Motor l

togg,ie switch was found in the OFF position after it had been returned to j

service. (DER 97-0759)  !

6 The MCC disconnect switch for the South Reheater Seal Tank Vent Line

isolation Valve (N2200-F701) did not have power fuses installed, causing it I

to fail to open on demand when operators attempted to place the South

Separator Seal Tank in service during plant startup. (DER 97-0758)

e MCC disconnect switch for Telephone Room Air Conditioning Unit

(X4101-B023) did not have power fuses installed. (DER 97-0617)

e RBHVAC was inadvertently tripped because of improper use of electrical

prints (DER 97-0593).

e Welding was performed in the reactor building during an SBGT surveillance

despite periodic announcements to prohibit such work. Charcoal filter

testing on April 18 confirmed that damage did not occur (DER 97-0541).

Additional examples can be found elsewhere in this report.

Self-identification of maintenance problems showed improvement during this

inspection period. However, the significant number of worker-induced equipment

problems, particularly those involving safety related equipment, was concerning.

The inspectors concluded that these examples were indicative of an adverse trend

in personnel performance during the conduct of maintenance.

During this inspection period, Maintenance worked to resolve two issues with

potentially high safety significance and a large number of components affected,

namely MCC switch lubrication / seismic qualification, and MOV motor pinion gear

inspection.s. Little assistance was initially obtained outside the Maintenance

organization on either issue. The inspectors noted that the Engineering staff

handled a number of significant issues of similar safety significance and magnitude i

in November-December 1996; inspection Report 50-341/96013 assessed those

efforts and concluded that the licensee effectively identified the significance and

magnitude of the problems and applied available resources, including industry

assistance, to resolving them. This markedly contrasted with the licensee's

performance in resolving the above two maintenance issues that were identified

during this inspection period.

M2 Maintenance and Material Condition of Facilities and Equipment

M 2.1 480 Volt MCC Disconnect Switch Problems

Significant problems had been noted with the manually operated fusible disconnect

switches used in ITE, Series 5600, motor control center (MCC) starters. For

proper operation, the switch must be closed and latched when equipment is in

operation or standby service. Opening the switches is normally required for

18

.

.

surveillances, maintenance, or other activities requiring systems or equipment

isolation. If the latching mechanism did not engage when the switch was closed,

the switch would usually reopen; however, if the switch stayed closed without

latching, as it dometimes did, the switch would open when subjected to a light tap

or vibration.

M2.1.1 Problem Descriglion and Corrective Action

a. Insoection Scoon

The inspectors reviewed records documenting problems with the fusible disconnect

switches and related MCC problems and discussed the problems with licensee

personnel,

b. Observations and Findinos

1

On April 9, following severallicensee identified instances of MCC fused disconnect

switches being found out of position open, the inspectors identified a concern with

the seismic qualification of these switches. The licensee notified the NRC per

10 CFR 50.72 on April 10. The inspectors reviewed selected DERs on the switch

problems and noted that the problems had been identified as early as 1992.

Detailed cause investigation and specific corrective actions were not taken.

Licensee personnel stated that the problems were not considered significant and the

failure rates were within the accepted failure rates for this type switch.

During the current forced outage, the licensee performed inspection, cleaning and

lubrication on all 1120 fusible disconnect switches. This was considered temporary

corrective action to allow operation of the equipment for the current operating

cycle. This action required operation of the switches and documentation of the as

found condition of the switches. Spray cleaner was then sprayed sparingly into the

switch pivot points and then was dried by air. A spray lubrication was then

sprayed into the switch pivot points and the switch was operated multiple times

untilit operated smoothly.

Problems with sluggish operation or the inability to close were noted with more

than 20 percent of the "as found" switches. Switches that would not close after

the cleaning and lubrication were removed from service and replaced. Several of

tmso replaced switches were disassembled and inspected. Hardened grease was

found in the pivot points of the disassembled switches. Grease from two of the

disassembled switches was analyzed and evaluated for the effect of mixing with

the spray lubricants and cleaner. These evaluations indicated that no problems

would be created with the mixing of the lubricants. Some problems were also

encountered during the implementation of corrective actions. These included an

ESF actuation involving safety-related ventilation caused by an inadequate work

impact review.

The cleaning and lubrication was considered to be temporary and licensee personnel

stated that permanent corrective action for the fusible disconnect switches was to

19

. _ _ _ _ _ _ - _ _ _ _ - - _ _ _ _ - _ - _ _ _ .

. 1

..

be determined at a later date. This is considered to be an unresolved item pending

review of the proposed permanent corrective actions (50-341/95003-04).

c. Conclusions

The corrective action process failed to recognize the significance of the switch

problem. The licensee was severely hampered by previous failures to document

difficulties in switch operation. In addition, there was a lack of communication and

coordination between the organizations involved in the investigation and

troubleshooting process. Systems engineers were apparently not aware of the )

sluggish operation or the inability of the switch to close that was experienced by l

plant operators. Maintenance assisted operators in getting the switches closed I

without work requests or other authorization and neither maintenance or operations

documented the problem. Inadequate communication was evidenced when

information, provided to the NRC inspectors during the temporary inspection and

cleaning of the switches was in progress, varied considerably between licensee

personnel. Criterion XVI of 10 CFR Part 50, Appendix B, " Corrective Action" l

requires that, for significant conditions adverse to quality, the cause of the

condition be determined and action taken to preclude repetition. The failure to l

recognize the significance of the problem and take prompt actions to prevent

recurrence is an apparent violation.

l

M2.1.2 Inadeauate Preventive Maintenance l

l

a. Insoection Scoca

Since the lack of preventive maintenance (PM) appeared to be a significant

contributor to the cause of problems with the fusible d;sconnect switches in the ITE

Series 5600 Motor Control Centers (MCC), the inspectors reviewed selected PM

records for the MCCs and discussed MCC PM with cognizant licensee personnel,

b. Observations and Findinas

l

The inspectors noted that the ITE vendor manual for the MCCs, VME5-7.1, l

Revision D, recommended that PM, including a visual inspection and manual or

electrical operations of MCC components, be performed twice per year. The

manual also recommended that a more extensive inspection and cleaning be

performed periodically, with the period not to exceed 18 months.

The inspectors reviewed the Sections of Procedure 35.306.008, " Motor Control

Center Load Compartment," Revisions 30 through 36, that applied to the MCC

fusible disconnect switches. This procedure did not specify the periods that the PM i

should be performed. Licensee personnel stated that portions of the procedure l

were performed at different times and that the PM frequencies varied from 18 l

months to 6 years. The vendor recommendation for twice a year visualinspection  !

and operation of MCC components was not addressed. Engineering justifications

for the variance in frequency or the acceptability of not performing the vendor i

recommended PM tasks did not exist. I

l

20 '

l

l

1

- -

_ _ _

- - - . . . - . .- - -- ...- -.

-

.. - - . = . - --. - . . -

1

-

,

l

-

2

4 During discussions, licensee personnel stated that, until recently, periodic operation

and cleaning of the fusible disconnect switches for the 480 volt starters was not

i performed if the individuals performing the maintenance did not consider it

i necessary. This portion of the PM task was performed at the option of the

j individuals performing the PM. Checks in the blocks for the fusible disconnect  ;

~

switch portion in the record copy of the procedure could be made to indicate either l

j that the switches were cleaned and actuated or that the switches were observed

l and looked "OK." The amount of PM performed on the control switches could not

j be determined from records.

i

a

inadequate PM on these MCC fusible disconnect switches was apparent from the

"as found" conditions of the switches. Over a period of time the switches became

~

dirty and grease became dry and hardened. This caused the switches to become

l difficult to close, sluggish to operate and, in some cases, the switches would close

'

but would not latch. As previously stated, unlatched switches would open with

vibration or a small bump resulting in the loss of power to plant components. The

480 volt MCC breakers affected the operation many important pieces of both

safety related and non-safety related systems and components through out the

i plant.

1

] c. Conclusions

!  !

It was evident from a visual inspection of the ITE 480 Volt MCCs that preventive l

!

!

maintenance of the fusible disconnect switches was inadequate. Previous

i violations had been written on problems with these MCC starters in the recent past.

i The actions taken on the identified violations were narrowly focused and the lack of

PM performance on the MCCs was not addressed. In addition, PM at the Fermi

i plant had been a significant issue during early operations of the plant. Lack of PM

i that has an effect of this magnitude on plant equipment indicates a possible overall

,

weakness in the PM program.

!

l The ITE 480 Volt MCCs affect the operation of valves and other components in

many plant systems. The failure to perform preventive maintenance on the ITE 480

'

volt MCC fusible disconnect switches, as required by Section 4.2 of

l Procedure 35.306.008, is considered an apparent violation of 10 CFR Part 50,

j Appendix B, Criterion V.

!

l M2.2 Failure of the Hiah Pressure Coolant Iniection Valve Resultod in Larae MOV

j Insoection Effort

a. Insoection Scoce

The inspectors reviewed the licensee's actions surrounding the failure of the HPCI

l Injection Valve (E4150-F006). This included reviewing the history of previous

j similar MOV failures, licensee's root cause determination, corrective actions, MOV

inspection results, and safety significance.

i-

21

,

i

- - , - - , - , , - v-n- - .,-- - - . - , - - - - . - - . - - - - - - - -

. _ _ . _ _ _ _ _ _ _ _ _ . _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _

i

-

1

)

i

s.,

j b. _ Observations and Findinas

i

i b.1 Event

s

l

During surveillance 24.202.05, "HPCI System Cold Shutdown Valve Operability

Test," on February 16,1997, while the plant was in a forced outage, the

l E4150-F006 failed to open on demand. The MOV was a 14-inch Powell flex wedge

!

gate valve equipped with an SB-3 operator. The licensee verified that the valve

.

open coil was energized and the motor was drawing current. At the valve, it was

i

noted that the motor was operating, however, there was no valve stem movement.

i The valve failure was attributed to a worn motor pinion gear set screw, such that

) the set screw no longer engaged the motor shaft to prevent the pinion gear from

" walking" up the shaft and disengage from the worm shaft helical gear.

1

I b.2 Backaround

I During the 1980's there were a number of MOV failures in the industry due to

i problems with the motor pinion gear key and set screw. At Fermi there were two

j examples of set screw problems. These included a set screw that backed out

,

(1987) and a cross threaded set screw (1993). In 1989, Limitorque issued

Maintenance Update 89-01, which recommended a fix for the set screw problems.

This included spot drilling a hole in the motor shaft and the use of locktite or lock

wire on the set screw to prevent it from backing out. The licensee was unable to

l find any documentation on how this maintenance update was addressed at Fermi.

j The licensee, however, did revise MOV maintenance procedures 35. LIM.004,

j 35. LIM.005, and 35. LIM.006, in 1988 to include the required fixes stated in the

i update.

!

l The NRC issued several Information Notices (IN) during the 1980's and 1990's that

'

addressed the problems with the motor pinion gear problems. During the licensee's

review of IN 94-10, " Failure of Motor-Operated Valve Electric Power Train due to

! Sheared or Dislodged Motor Pinion Gear Key," as documented in Operating

i

Experience Report Disposition Memorandum 94-76, dated August 22,1994, the

l licensee identified five issues that needed to be addressed. These issues included

! incorrect assembly of motor pinion gear to new motor shafts, inadequate strength

4 of motor pinion key stock, lack of motor pinion set screw countersink on motor

i shaft, lack of staking on end of motor shaft at keyway, and lack of lockwire holding

l the pinion set screw. The disposition indicated that "Many MOVs in the plant have

! " suspect" conditions leftover from the late 70's, early 80's inadequate assembly

,

techniques." The licensee's philosophy was that the maintenance update would be

incorporated in the MOVs "when an opportunity presents itself," (i.e., motor

3

removed for other work). The memorandum atro concluded "there is still a risk of

l failure on many existing MOVs." The licensee 1, preventive maintenance program

3

for MOVs, however, did not require the motor to be removed on a specified

frequency. As such, for the HPCI injection valve, the motor shaft was not spot

,

drilled, nor was there a schedule in place to have the shaft spot drilled (the set

i screw was lockwired).

!

4

l 22

I

!

!

~ __ _ . - -

_ _ _ _ _ _ _ _ _ _ _ _

.

.

The inspectors considered that LER 97-002, " Failure of the High Pressure Coolant

Injection System Pump Discharge Valve to Open," was misleading when it stated

"The spot drilling for pinion gear set screws is being systematically implemented at

Fermi 2, but work on valve E4150-F006 had not yet been performed..." since the

spot drilling of motor shafts was not specifically scheduled. Maintenance records

were not sufficiently detailed for the licensee to determine how many motor shafts

had been spot drilled, or set screws lockwired or used locktite. This issue

potentially affected 187 safety-related MOVs. During the inspection, the licensee

also stated for another MOV generic issue involving the key material, ANSI 4140

versus 1018, that they did not have documentation to verify that all valve keys

were of the proper material. The key material, however, did not play a part in this

failure.

b.3 Corrective Actions

The actions taken and/or planned by the licensee were considered good.

Approximately 64 safety significant valves were inspected to ensure the spot

drilling was in place. The valves were chosen based on their safety significance,

which was determined from the Probabilistic Risk Assessment or from a review of

the Maintenance Rule systems, structures and components. The licensee evaluated

the results of these inspections, and determined no subsequent inspections were

warranted prior to startup. The remaining approximately 120 safety-related and

important-to-safety MOVs were to be inspected during the following 2 outages.

b.4 Safety Sianificance

This was a generic concern for all MOVs in the plant and could have introduced a

common-mode failure that could potentially affect multiple systems. The failure of

the HPCI injection valve would prevent automatic operation of the HPCI system and

the system would not function as designed to provide a source of high pressure

flow to the core to mitigate the effects of a small break loss of coolant accident.

This valve was located in an inaccessible part of the plant during operation and

accident conditions. In the event HPCI failed, RCIC and the remaining emergency

core cooling (ECCS) systems should be available to mitigate the accident. The

Automatic Depressurization System would be available to reduce reactor pressure

such that the low pressure core spray and RHR systems would be able to inject into

the reactor system.

c. Conclusion

The licensee was not timely in resolving a known industry issue when the

corrective actions recommendations were issued by the vendor in 1989. As a

result, the HPCI E4150-F006 MOV failed to open on a demand signal from the

control room. The failure mechanism was a generic concern for all MOVs in the

plant and could have introduced a potential common-mode failure. This was

considered an apparent violation of 10 CFR Part 50, Appendix B, " Corrective

Action" for failure to implement corrective actions for a condition adverse to quality

in a timely manner.

23

. . -. - -. . . - - . . - _ _ . -. . - _ . _ - _ . . - -

,

.

M2.3 24/48 Volt Batterv Cells Reolaced Without Beina Fully Charaed

"

a. Insoection Scoce (62703,92903)

The inspectors reviewed the recent maintenance history for the 24/48 volt battery.

j Electrical maintenance supervision, Planning and Scheduling Supervisor, and the

system engineer were interviewed. The design basis document, operator logs, and

• surveillance results were reviewed to determine battery operability. Administrative

procedures for work control and surveillance were reviewed to determine if proper

controls were in place, and completed work packages were then reviewed.

4

b. Observations and Findinas

The Division 124/48V battery had three cells replaced (a single jar) under

1 WR 000Z964874, but the cells were not properly charged prior to returning the

battery to service on February 12. This was not recognized until March 20, when a

,

quarterly battery check surveillance (job AB62961219) identified that the new cells

i failed to meet the minimum required individual cell voltage (ICV) of se2.13V by

i 0.01V. The system engineer recommended charging the entire battery to restore

the low ICVs, but this was unsuccessful, so the cells were replaced,

i

' The electricians assigned to install the cells determined that they required additional

! water charging before installation. From experience, they knew that batteries

should be charged following the addition of water. This work was performed and

noted in the remarks as " shop work" in the WR 000Z964874. The inspectors

determined that the work package was not changed to include this work scope

addition.

The inspectors reviewed WR 000Z964874, and discussed the event with the

system engineer and electrical maintenance supervisors. The inspectors noted that

WR 000Z964874, which specified performing steps from maintenance procedure

35.310.02,"24/48 VDC Electrical System - General Maintenance," did not contain

! any instructions to perform pre-installation checks to ensure the new cells were

ready to perform their intended function, such as electrolyte level and specific

gravity checks, or charging the new cells.

,

The system engineer stated that spare cells maintained in stock offsite were

charged every 6 months. While investigating this problem, the system engineer

' identified that the new cells had last been charged 5 months previous to

installation. DER 97-0480 was written by the system engineer upon discovering

the electricians had charged the new cells at the wrong voltage.

The vendor manual required charging at 2.33 - 2.38V per cell, but

3

WR 000Z964874 indicated that charging was performed at 2.17 volts per cell.

The inspectors determined that the electricians consulted neither the vendor manual

nor the system engineer in determining the voltage to charge the new cells, but had

instead reasoned a value from operating parameters. System engineering

l

!

4

24

__ . ._ ___

.

l

-

\

performed an operability assessment and determined that the Division 124/48V

battery was operable.

The PMT for 000Z964874 specified performing 24/48VDC Weekly Battery Check

(47.310.03), but the inspectors identified that this procedure did not require

checking the ICVs and specific gravity for the newly installed cells (only for the

pilot cells). This deficiency was not identified by the work group supervisor or the

NSS during PMT review. In discussions with the inspectors, the Electrical

Maintenance Supervisors and the Work Planning Supervisor agreed that the PMT

specified was inadequate to verify the new cells were in a proper condition.

Licensee corrective actions planned for this event were to revise the battery

installation procedure to include cell preparation steps, including charging new cells

before installation.

The inspectors reviewed the DC Electrical System Design Basis Document and

determined that the 24/48V batteries perform support function for safety related

loads. The batteries provide backup power for four hours on loss of all AC power

to neutron monitoring and process radiation monitoring instrumentation. The

inspectors reviewed the operability determination for the as-found condition of the

battery and support documentation, and concluded that the battery retained

sufficient capacity to perform its function.

The inspectors reviewed MWC02, " Work Control," and determined that it did not

prevent performing shop work or preparation work without steps in the work

request.

c. Conclusions

The inspectors concluded that WR 000Z964874 and Maintenance Procedure

35.310.02 were inadequate to ensure new battery cells were installed in a l

condition to support the function of the battery. This was considered an example  ;

of a violation of Technical Specification 6.8.1.a and Regulatory Guide 1.33,

" Quality Assurance Program Requirements (Operation)." (VIO)(50-341/97003-05)

The inspectors were concerned that this WR relied heavily on craft skill of the

workers. Previous concerns about the quality of electrical maintenance procedures

were documented in Inspection Reports 50-341/95012 and 50-341/96010, each of j

which resulted in a violation. This continued to be a concern.

1

The inspectors considered that the licensee's work control procedure was weak in l

that pre-job steps were not specified or documented in a standardized manner, in

this example, preparation steps were not specified, but were performed and

documented by workers without revising the WR for the change in scope. The

inspectors determined that this practice was not precluded by the work control

procedure, but was considered a programmatic weakness.

25

1

- _ _ _ _ . - _ - _ _ _ _ _

.

.

M 2.4 Shiocina Pluas Found in Plant Transmitters

The inspectors conducted walkdowns of various plant locations

and noted that shipping plugs were found installed in some transmitters in the .

plant. The inspector reviewed documentation that showed that shipping plugs had l

been removed from both safety and environmentally qualified transmitters. l

However, the inspectors were concerned with the scope and the application of the i

remaining transmitters with installed plugs. The concern was that the installed

plugs would degrade and allow moisture, dust or dirt to enter, potentially resulting

in transmitter failure.

The inspector noted that in some cases sealant was being used over plugs.

Moreover, the inspector noted that for some important safety transmitters it could

not readily be determined if a metal plug has been installed due to the presence of a

non-trarisparent sealant. The inspector was also concerned that shipping plugs

might remain in transmitters for nonsafety related equipment used during abnormal

and emergency operating procedures. Some of the affected transmitters include

those associated with Main Steam Leakage Detection System, Main Steam System,

and Reactor liuilding Closed Loop Cooling Water System flow indication.

The inspectom will continue to evaluate the scope and application of the

transmitters that may be affected, as well as previous corrective action for the

issue. This will be tracked as an Inspection Followup Item. (IFI)(50-341/97003-06)

M3 Malntenance Procedures and Documentation

M3.1 Emeraency D esel Generator (EDG) Station Air Comoressor (SAC) Left in Off

a. Insoection Scone (92901)

The inspectors performed an independent evaluation of the causes and corrective

actions for an EDG 11 Starting Air Low Pressure alarm. Emergency diesel

generator operability during the event was evaluated by reviewing operator logs,

annunciator response procedures, technical specifications (TS), and the system

operating procedure (SOP). Planned corrective actions were reviewed, as were the

results of subsequent findings. The surveillance procedure was reviewed and

compared with administrative controls for operation of equipment to determine the

adequacy of the procedure. The event and corrective actions were discussed with

Operations management.

b. Observations and Findinas

On April 2, a non-licensed operator performed a routine oil sample of the starting air

compressor for EDG 11. The operator knew from experience that the compressor

oil level might go below the minimum operating oil level while removing a sample,

although the surveillance sheet did not include a caution in this regard. To ensure

the compressor would not start while sampling the oil, the operator turned the

compressor off locally, without informing the control room. Several hours later, the i

)

26

l

1

l

l

l

i

l

.

.

EDG 11/12 Starting Air Tank Pressure Low alarm was received in the control room.

Per the annunciator response procedures, an operator was dispatched to

investigate. The operator identified that EDG 11 air pressure was 220 psig and the

SAC local switch was out of position in OFF. The starting air pressure was

maintained above the TS minimum allowable pressure during this event (215 psig),

so EDG 11 remained operable. A valve position verification was performed for the

remainder of the EDG 11 starting air system, with no additional discrepancies

noted. The compressor was started and air pressure restored.

The I censee's investigation determined that the operator taking the oil sample had

forgotten to restart the compressor due to inadequate self-checking and a weak

procedure. By not informing the control room of the actions, the operator

prevented possible backup by other members of the shift from detecting the error.

There was no pre-job brief conducted for this work.

The inspectors determined that MOP 02, " Independent Verification," Step 3.2.1.3

required that an independent verification be performed in this situation.

Specifically, that step stated that equipment important to safety shall have

independent verification performed to ensure that equipment, valves, and switches

that were placed in an abnormal position are correctly aligned. The inspectors

identified that Surveillance Job AF11970403 did not include appropriate

instructions to turn off the SAC for equipment and personnel safety during oil

sampling, nor did it include independent verification for return to service.

The inspector discussed the event with the Operations Superintendent. Deviation

Event Report 97-0502 was written for Operations to take a broad look at the

control of equipment during work not covered by SOPS. Operations reviewed all

237 preventive maintenance events assigned to Operations and identified 32 events

that required additional instructions to properly perform the jobs, including events

which should have required independent verification steps but did not. Additional

reviews assigned to Radiation Protection (RP), Chemistry, Maintenance, and System

Engineering were stillin progress at the conclusion of this inspection.

c. Conclusions

The inspectors concluded that EDG 11 remained operable throughout this event due

to the continuous availability of an adequate supply of starting air within TS- l

required pressure limits. The inspectors considered the licensee root cause

determination to be adequate, and the corrective actions sufficiently broad to

address the larger issue; namely, the proper configuration control of safety related

equipment during evolutions which do not constitute a complete, formal procedure.

The inspectors concluded that the operator missed an opportunity to identify that

the work instructions were deficient and have the procedure changed.

Inspection report 50-341/97002 documented inspection findings of weak

configuration control during troubleshooting. The inspectors considered this event

to be an additional example of configuration control weaknesses during work ,

activities. I

27

_ _ - - .

- - .- . - _

_ .- - - - - . .

.

O

The inspectors concluded that work instructions in PST job AF11970103 were

i

inadequate to safely perform the oil sample and ensure the SAC was restored to the

proper lineup and verified as required. This was a violation of 10 CFR Part 50,

Appendix B, Criterion V. (VIO)(50-341/97003-07)

M7 Quality Assurance in Maintenance

M7.1 Licensee Self-Assessment Activities (40500)

a. Insoection Scoos (4050_Q1

The inspectors reviewed multiple licensee self-assessment activities. On-Site l

Review Organization (OSRO) review of various safety issues, including MCC fuse

disconnect switch issue, were observed for effectiveness and compliance with TS

,

requirements (see M2.1).

b. Observations and Findinas

,

The inspector questioned station management concerning the lack of an initial

review of the MCC fuse disconnect switch issue by OSRO committee before

activities were implemented to correct the unlatching problem. In response to

inspector concerns, the plant manager referred the issue to OSRO for review.

! The inspector observed the OSRO meetings and questioned the conduct and

'

effectiveness of the committee. For example, the inspector observed that some

questionable laboratory results were not fully questioned to gain a complate

understanding of the issue. Specifically, the interaction of the cleaning solvent with

the existing grease accelerated the hardening of the grease. OSRO did not

,

questioned the significance of these results. Other pertinent information not initia!!y

'

or fully discussed by OSRO included issues related to other failures of the fuse

disconnect switches, seismic qualification, MCC inspection findings, and the

relationship between root cause and corrective action. After the OSRO meeting, an

I anonymous DER was written discussing concerns with the effectiveness of the

OSRO meeting. Senior plant management was addressing this DER.

c. Conclusion

!

The inspectors concluded that the On-Site Review Organization was initially

ineffective in resolving issues associated with MCC Fused Disconnect Switch.

Corrective actions were implemented on a substantial portion of the affected

population before the adequacy of the corrective actions were adequately assessed.

The inspector was concerned with the effectiveness of the OSRO committee to

perform special reviews, investigations or analysis, and reports requested by the

plant manager as required by Technical Specification 6.5.1.6. This will be tracked

as an Unresolved Item pending review of licensee corrective actions for improving

OSRO effectiveness. (URI)(50-341/97003-08)

i

28

- __ _ _ _ - ._ _. - _ _ _ _ . _ _ _ - . - - - . - _ - . - . _ .

.

1

-

i

M8 Miscellaneous Maintenance issues (92902)

M8.1 (Ocen) Follow-Uo item 50-341/96016-04: Review of licensee practices for

protecting equipment inside containment from inadvertent damage during outage

work. During this inspection, the licensee concluded that the RCIC Steamline

Inboard Isolation Valve (E5150-FOO7) became stuck in manual operation because

the declutch lever was stepped on, requiring MOV disassembly to repair the

actuator. The valve was located inside the drywell in an area that was difficult to

traverse. This was considered to be an additional example of safety related

equipment inside the drywell that was inadvertently damaged during outage work. )

The inspectors observed drywell work during this inspection period and found that l

there was little scaffolding installed for personnel access, and the scaffolds that I

were installed were only in specific work areas. Equipment in non-work areas l

which were difficult to access remained vulnerable to being stepped on. The

l

vulnerable areas included the area near the main steem lines and most areas above

the main floor. In response to the latest failure, the licensee issued a site-wide

reminder to avoid stepping on plant equipment and to report any potential damage

to the control room. The inspectors noted that climbing on equipment in the certain

portions of the drywell was unavoidable if scaffolding were not installed. The

inspectors will continue to review drywell equipment performance and licensee

actions to avoid incidental damage to this equipment. This item will remain open.

M8.2 (Closed) Unresolved item 50-341/97002-04: NRC review of MOV Motor Pinion

Gear Inspection Results. Licensee inspections of 67 MOVs deemed important to

safety identified:  !

e 10 motor shafts had not been spot drilled.

!

e 15 keys were not properly staked to the shaft (only one key was found

protruding from its expected position). 1 1

1

1

e All set screws were secured with either lockwire or Locktite.

• 14 set screws were found "slightly" loose. Set screws were tightened up to

half a turn.

e 1 motor pinion gear key was missing.

The deficiencies noted during the inspections were corrected and the valves

retested prior to their return to service. The licensee concluded that the corrective

actions dramatically reduced the pinion gear failure potential for the safety j

significant valves that were inspected. However, the inspection results did not I

warrant the immediate corrective actions to additional MOVs. Based on the

inspection results, the lower safety significance of the remaining affected MOVs,

and a schedule to incorporate the corrective actions over the next two refueling

cycles, the inspectors considered this acceptable to maintain MOV operability in the

29

. - _ _ _ _ _ - _ - _ _ _ _ - _ - _ _ _ -

i ,

l l

(. I

l

.

plant. The concern with failure to take proper corrective actions from previous

l

identification is addressed in Section M2.2 of this report. '

l

lil, Enaineerina j

E1 Conduct of Engineering l

E1.1 Inadeauate EDG Loaic Testina

a. Insoection Scone (92902)

Modifications were reviewed to ensure that safety evaluations were performed

satisfactorily, necessary approvals were obtained when required, engineering

documents and procedures were included when required, and post-modification

testing was correctly identified and completed,

b. Observations and Findinas 1

Enaineerina Desian Packaae (EDP) No. 8355

The licensee identified that non-essential EDG trips, such as tube oil high

temperature, were not automatically bypassed by the "A" start circuit if the "B"  :

start circuit failed. Fermi's UFSAR stated that there were two emergency start l

circuits: either of these relays willinitiate EDG starting as well as bypass the I

unnecessary trips. This modification was field completed on June 1,1989. I

The licensee added a SEX emergency start isolation relay to each EDG start circuit.

These relays were normally de-energized during EDG operation. Normally closed

contacts (1/2) were added to the "A" start circuit and (5/6) were added to the "B" I

start circuit. The two start circuits were provided to increase reliability, and met

the requirements of the Institute of Electrical and Electronic Engineers (IEEE)

Standard 387 - 1977, "lEEE Standard Criteria for Diesel-Generator Units Applied as

Standby Power Supplies for Nuclear Power Generating Stations." If an essential .

EDG trip had occurred, such as high differential generator current, relay SEX would l

be energized and prevent automatic start of its associated EDG. During an I

automatic EDG start, either the ESA or ESB emergency start relays would bypass l

the non-essential EDG trips. The loss of a single start circuit would not prevent l

automatic start of it's associated EDG if a non-essential trip had occurred. l

l

The licensee had identified in 1994 (LER No.94-003) that past logic testing

practices did not ensure that proper test overlap existed between procedures. A

logic test should test all components, such as relays and contacts, from the sensor

through and including the actuated device. The test may be performed by any

series of sequential, overlapping or total system steps so that the entire logic

system would be tested. As part of Fermi's corrective actions, the licensee

reviewed numerous surveillance and test procedures. Procedures were revised and

untested components were tested. No component failures were identified.

30

l

_____J

- . __ ___ _. _ _ _ _ _ _ _ . _ _ __

.

.

The inspectors reviewed surveillance procedure No. 42.307.01, Revision 22, " Logic

System Functional Test of Division i EDG ECCS Emergency Start Circuits and Auto

Trip / Bypass Circuits." Since all of the EDG start circuits were similar, the start

circuits for EDG No.11 were reviewed in detail. The inspectors concluded that the

licensee was testing all circuit logic paths and components in an acceptable

manner.

The inspectors reviewed the testing performed during the implementation of

EDP 8355. This included work request No. 0058881107, the electrical scheme

chockout performed on April 26,1989, and the post-modification test perforrded on

May 25,1989. During the review of the test procedures, the inspectors

determined that 5EX relay contacts (1/2) had not been verified in their open state i

and that contacts (5/6) had not been tested in their open and closed states. These l

contacts were now appropriately tested during surveillance 42.307.01. I

1

I

c. Cpnclusions j

The licensee's failure to appropriately test the SEX contacts during the modification

process is considered a violation. However, the licensee identified inadequate

overlap testing during routine surveillance procedure reviews. In addition, the

licensee initiated comprehensive corrective actions as identified in LER No.94-003.

This included the evaluation and implementation of necessary changes to control

plant modifications and procedure revisions to ensure test overlap was reviewed.

Therefore, this item will not be cited because the requirements of Section Vil of the  !

I

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600, were met. (NCV)(50-341/97003-09) The inspectors concluded that

the licensee had taken appropriate corrective actions to ensure electrical and

instrumentation & control test overlap would be considered during future

modifications and test procedure reviews.

E2 Engi:neering Support of Facilities and Equipment

E 2.1 LiGfLnsee Identified and Corrected Several EECW Desian Deficiencies

'

During work associated with the preparation of engineering design package for the l

EECW make up tank, the licensee identified the following issues:

• Certain single failures of a divisional power source could result in loss of the

, primary containment function for EECW subsystems. All primary

,

containment iso!ation valves within a division were powered from the same

source. On loss of one division of AC power, the Primary Containment

Isolation Valves (PCIVs) would fail as-is in the open position. The isolation

valves which separate EECW from RBCCW could also fail open in this

situation.

,

,

e The EECW piping inside the drywell was not safety grade material. The

EECW design was such that the integrity of this piping was not relied upon

'

during an accident. so it was not analyzed for the ability to withstand a high

31

.__ __

l

.

e

l

'.

energy lirio br9ak (HELB). Because the PCIVs were found to be susceptible i

to failure, a high energy line break coupled with a loss of AC power could l

potentially release fission products into the secondary containment, or if the l

RBCCW isolation valves were open, to the environment.

• Also, the licensee identified that the Remote Shutdown System, for use in a i

fire which disrupts plant operation from the main control room, did not I

include controls to isolate RBCCW from Division 1 EECW. This could  ;

potentially have prevented initiating EECW, because an interlock required the

RBCCW isolation valves to shut before the makeup tank isolation valve could

be opened.

The licensee reported these issues to the NRC in accordance with 10 CFR 50.72.

During this inspection period, engineering conducted analyses of the impact of

potential HELBs on the EECW system, and eliminated all potential sources except

one. A modification to protect the susceptible section of EECW piping was

installed in the drywell.

Additional modifications were installed to provide diverse power sources to EECW

PCIVs in each division in order to restore the primary containment isolation

function, and to the Remote Shutdown System to allow proper operation of the

EECW system.

These issues have been reviewed by the Resident inspectors, Region lll and NRR

personnel as the issues were developed and resolved. Additional review of the

licensee's analyses will be performed by NRR. This issue will be tracked as an

Inspection Followup Item pending the completion of reviews by NRR.

(IFI)(50-341/97003-10)

E2.2 Reactor Protection System (RPS) Resoonse Time Testina

NRR identified that a conflict existed between RPS response time testing as

described in technical specifications and the testing performed by the licensee as

documented in the Technical Requirements Manual (TRM). Specifically, TS required

testing the entire response time, while the TRM allowed using nominal sensor

response times and measuring the response time of the rest of the circuit. The

TRM had been changed with a 50.59 safety evaluation based on the Boiling Water i

Reactors Owners Group Licensing Topical Report NEDO-32291, " System Analyses l

for the Elimination of Selected Response Time Testing Requirements" as approved

by NRC Safety Evaluation Report.

The licensee then determined that response time testing of Reactor Protection

System Actuation Instrumentation, Isolation System Actuation Instrumentation, and

ECCS Actuation Instrumentation had not been conducted in accordance with

Technical Specification requirements. As a result, the licensee declared associated

ECCS systems inoperable, established secondary containment and performed l

response time testing. All equipment was found to be functioning as expected.

!

32

i

l

J

-. . . . . - . . .- -- . _- . -- .

.

.

The licensee requested and received a licensee amendment to modify the TS

definition to allow performance of response time testing as specified in the TRM. l

l

The technical specification compliance issue and process used by the licensee to j

'

make changes to technical requirements will be reviewed by Region lil inspectors.

These issues will be tracked as an Unresolved Item pending completion of Region lli

review. (URI)(50-341/9700311) l

1

l

IV. Plant Sucoort j

1

F3 Fire Protection Procedures and Documentation

F3.1 Fire Protection Surveillance Weaknesses )

I

a. Insoection Scoce (61726)

The inspectors reviewed procedures associated with surveillance 28.501.04, " Fire

Suppression System Valve Operability Test." The inspectors observed both control

room and in field implementation of the fire protection surveillance. The inspector

reviewed the Updated Final Safety Analysis Report (UFSAR), and the fire protection

plan.

b. Observations and Findinas

On April 4 the inspectors observed performance of the Fire Suppression System

Valve Operability Test. The test required that various fire protection valves be

unlocked and fully closed, then fully opened. in addition, the performers were 4

required to verify the appropriate OS&Y CLOSED light Indicated correctly for valves

with tamper switches. The inspector noted the FIRE DET/ PROT System Trouble

annunciator was not received as expected for valve T80-F030,2nd Floor Cable  ;

Tray Area Sprinkler System Isolation Valve. A work request was written to repair i

the alarm.

The inspector reviewed annunciator response procedure 16D28 to verify that

switch T80 N011 did input to the alarm. The inspector reviewed the UFSAR and

noted that the UFSAR did not require verification of the alarm. However, the

inspector concluded that the control board annunciator was an expected and

necessary response to ensure control room operators were alerted to problems with

the fire protection system. As a result, operations requested revising the

4

surveillance procedure to perform verification of annunciators for all valves with

alarms.

,

c. Conclusions

The inspector concluded that the lack of verification of the annunciators was a

weakness in the surveillance for fire protection system operability. The inspectors

33

1

.

!

'

l

.

concluded that the licensee's decision to include the testing of the control board fire

protection trouble annunciator was acceptable.

R1 Radiological Protection and Chemistry Controls

R 1.1 Valve with Internal Contamination Released from Radioloaically Restricted Area

(RRA)

1

a. insoection Scoce (71750) l

l

The inspectors reviewed data concerning the release of an Offgas System valve to

the clean machine shop. The inspectors interviewed personnel and reviewed area

surveys.

l

b. Observations and Findinas

Station mechanical maintenance personnel removed two valves from the Offgas

System to perform repairs. The valves were surveyed by RP, found to have no

contamination, and released to the cold machine shop. Following disassembly of

the valve, the maintenance technician requested RP to resurvey the valve internals.

The survey identified that the internals of the valve were contaminated. Radiation

protection personnel immediately returned the valve along with tools and parts to

the count room to perform additional surveys, in addition, the maintenance ,

I

technician's clothing, personal affects, and machine shop area were surveyed and

no contamination was found.

The licensee was conducting an investigation at the end of the inspection period.

The inspectors noted that the issue was raised due to the questioning attitude of a

maintenance worker.

c. Conclusions

The inspectors reviewed the licensee's immediate corrective actions and determined

that they were acceptable. This issue will be tracked as an Unresolved Item

pending review by a Region 111 specialist inspector of procedure adherence and

procedural adequacy of surveying component intervals. (URI)(50-341/97003-12)

l

R 1.2 Backfill System Placed in Service Without RP Briefina on Radioloaical Conditions in

the Work Area

a. Insoection Scooe (71750,61726)

The inspectors observed performance of a surveillance which filled and vented a

potentially contaminated instrumentation system located inside a radiation area.

The inspectors observed radworker practices, compliance with radiation work

permit requirements, and exposure control measures. When a concern was I

identified, the inspectors reviewed station procedures for work outside normally l

34

__ _ __ _. _ _ ._ - _ _

_

.

. .

( surveyed areas of the plant, scaffolding procedures, and discussed the concerns

with RP supervision,

b. Observations and Findinos

On May 4, the inspector observed l&C technicians placing the Division 2 Backfill

system in service. The inspector observed that the work was done in a careful

manner, using excellent communications and radiological precautions while venting

this potentially contaminated system.

J

However, the procedure required us;ng a portable lift to operate the supply header

isolation valve (B21-F2408), which was located about 15 feet above the floor. The

inspector reviewed Radiation Work Permit (RWP) 971011, which was the Specific

RWP in use for this job. The instructions required workers to notify RP if climbing

or going above 8 feet. The inspector observed that the RWP package at the

worksite had four survey maps, none of which included the work area 15 feet  !

I above the floor. The inspector asked the work group leader about the use of the

lif t, who stated that the workers had not contacted RP prior to beginning work

because the same workers had been working in the same area for the previous

3 days and were familiar with the radiological conditions.

The inspector discussed the issue with the RP Shift Supervisor, who stated that the

requirement to contact RP prior to going above 8 feet was not met in this case.

The RP expectation was that workers were expected to contact RP every time they

went above 8 feet. DER 97-0722 was written to document the event and track

corrective actions. The individuals involved had their access to the RRA removed

pending review.

The inspector further discussed the event with the workers and RP staff and

determined that the workers were knowledgeable of the work conditions because

radiological conditions had not changed since their briefing from RP the previous I

day. Additionally, workers were monitored for radiation dose.  !

>

c. Conclusions 1

i

The inspector concluded that failure to notify Radiological Protection personnel )

before gaining access in an area greater than eight feet above the floor was a i

violation of 10 CFR 20.1101. This resulted in the radiological workers not j

obtaining a briefing on radiological conditions in the entire work area.

(VIO)(50-341/97003-13)

I

R1.3 Post Accident Samole Error

I

a. Insoection Scone (71750,61726)

The inspectors observed the operation of the Post Accident Sample System (PASS) 1

during a surveillance. The inspector reviewed the surveillance procedure and

training records for individuals qualified to operate the system. When the system

35 )

4

_ _ _ . . .

.. -- . . .- - . _. - --- _ .-- _

i.

e

i did not produce a sample, the issue was discussed with the system engineer and

,

chemistry supervisor.

'

b. Observations and Findinas

The inspector observed a semi-annual sample obtained from the PASS on April 25.

The technician failed to obtain a sample the first time because the sample bottle

was not properly installed.

i

! The licensee stated that the procedure (78.000.12) would be changed to have the

" Bottle In" light verified green, but the inspector noted that a caution on the topic

already existed in this procedure. In a discussion with the system engineer, the

, inspector learned that the microswitch which ensured that sample bottle was

correctly positioned had frequently caused difficulty obtaining a sample unless great

care was taken in inserting the sample bottle. However, the indicator light was

available to allow determination of correct alignment.

The inspector reviewed the PASS sampling procedure and determined that it

required that personnel performing PASS samples be qualified to use self contained

breathing apparatus. Respirator qualifications were checked for personnel qualified

to operate the PASS system, and the records indicated that the individual observed

and one other had expired self-contained breathing apparatus qualifications in

January,1997. The licensee subsequently determined that both individuals had

recently recertified, and that records had not yet been updated.

c. Conclusions

l, The inspector determined the chemistry technician was knowledgeable of the

sampling procedure. The PASS system functioned as designed, but operator

attention to detail had prevented obtaining a sample on the first attempt. However,

the inspectors considered that the administrative controls used to ensure proper

! training to operate the system during accident conditions were weak.

R 1.4 Untimelv Restoration of Unfettered Access for NRC Insoector

b. Observations and Findinos

During observations of performance of RCIC surveillances, an inspector lost control

of both the assi0ned dosimetry and security key-card identification badge. The

incident occurred while the inspector was exiting a vital area into an non-vital area '

within the RRA. Both the badge and dosimetry remained within the vital area while

the inspector exited the RRA. Shortly later, station personnel discovered the

uncontrolled badge and notified security parsonnel as required by procedures.

Security personnel quickly located the inspector and conducted an investigation of

l the circumstances as required by procedure MRP08, "RRA Access

'

Denial / Reinstatement," Revision 1, dated October 2,1996.

<

36 l

-- . . - - - -. - -- - -- - _ _ . .-

.

.

i Security personnel were able to ascertain through interview of the inspector that

'

the inspector had accidently lost the badge and was unaware of the condition until

notified by security personnel. The security staff was also able to determine

through review of computer records that the badge had not been used or attempted

to be used by any persons while it was in a uncontrolled status.

! RP personnel also conducted an investigation of the circumstances as required by

MRP08. RP personnel were able to determine from recent surveys of the

inspector's egress path that unaccounted dose was not received by the inspector.

i After both the security and RP personnel had completed their investigation, the

reinstatement requirements of MRP08 were verified to be met. These requirements

were verified within a half-nour of the initial incident. However, because of the late

hour on a weekend, approval for reinstatement of access was not obtained in a

< timely fashion to allow the inspector to observe the assigned activity. Although the

licensee's authorized representative for signature and approval of reinstatement of

RRA access was notified of the completed investigation in a timely fashion,

reinstatement of the NRC inspector was denied. The authorized individual, the on-

shift NSS, believed that reinstatement required at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the next work

day and denied access for the inspector to conduct inspection activities. After

prompting by the inspector and the RP personnel present, approval was obtained

from offsite senior management.

1

c. Conclusions

The inspector determined that the procedure MRP08 did not allow for timely

3

compliance to 10 CFR Part 50.70 requirements. The procedure did not ensure that

l a duly authorized representative of the Commission was permitted to inspect the

assigned activity. Although the inspection was eventually complete via other

means, such as record review, the procedure MRP08 did not ensure timely access

during off-normal hours. This is an unresolved inspection activity pending further

! review of licensee actions to ensure that access can be obtained in a timely fashion

to allow inspection of licensee's activities by duly authorized NRC inspectors.

t

(URI)(50-341/9700314)

S1 Security and Safeguards Activities

S 1.1 Temocrary Backaround Checks Used Bevond 180 Davs

The licensee identified that a contract worker had exceeded 180 days on a

temporary background check. This was documented in DER 97-0606. Tha

>

individual was granted temporary access at the beginning of Refueling Outage 05,

and left six weeks later. The individual came back for Forced Outage 97-01 in

January 1997, while the temporary background investigation was still valid, but the

allowed 180 day period expired on March 30. The expiration was not recognized

until April 16, at which time the individual's access was removed. The event -nas

determined to be a loggable event. A further review by security identifed three

more individuals with temporary access beyond 180 days, whose access was also

i

37

.

l

.

removed. The full background checks were subsequently completed and the

individuals' access restored.

This event will be tracked as an inspection Followup Item pending review of the

circumstances surrounding the event and evaluation of licensee corrective actions

by Region 111 Security Specialist inspector. (IFI)(50-341/9700315)

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on May 9,1997. A subsequent exit was conducted on

June 26,1997, to address resolution of issues after management review of the report.

The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

l

i

l

1

,

J

l

J

i

!

i

i

38

_

_

. .- -. .. - -. -. - - . - .-

l

l

. .

PARTIAL LIST OF PERSONS CONTACTED

'

Licensee

! S. Bartman, Supervisor, Chemistry

i

S. Booker, Superintendent, Electrical Maintenance l

P. Borer, Assistant Vice President, Nuclear Generation

C. Cassise, General Supervisor, Mechanical Maintenance l

D. Cobb, Superintendent, Operations

R. Delong, Superintendent, System Engineering

P. Fessler, Plant Manager, Operations

~

D. Gipson, Senice Vice President, Generation

T. Haberland, Superintendent, Work Control

R. Matthews, Superintendent, l&C Maintenance

J. Moyers, Director, Nuclear Quality Assurance

N. Peterson, Supervisor, Compliance

J. Plona, Technical Director

'

T. Schehr, Engineer, Operations

i NBC

! None

l

l

4

l

l

4

,

4

39

,

-

_ ._ __ __. __ __.

5

.

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing

Problems

IP 61726: Surveillance Observations

IP 62707: Maintenance Observation

IP 71707: Plant Operations

IP 71714: Cold Weather Preparations

IP 71750: Plant Support Activities

IP 92901: Followup - Operations

IP 92902: Followup - Engineering

IP 92903: Followup - Maintenance

IP 92700: Onsite Followup of Written Heports of Nonroutine Events at Power Reactor

Facilities

IP 93702: Prompt Onsite Response to events at Operating Power Reactors

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened

50-341/97003-01 IFl Review of FME practices

50-341/97003-02 VIO Inadequate procedure to restore RCIC to proper lineup

50-341/97003-03 URI Review safety implications of using non-sequential procedure

steps for testing

50-341/97003-04 URI Review of permanent corrective actions of MCC disconnect

switches lubrication issues

50-341/97003-05 VIO Inadequate procedure to install fully ready battery

50-341/97003-06 IFl Review transmitter shipping plugs

50-341/97003-07 VIO Inadequate procedure for EDG 11 air compressor oil sample

50-341/97003-08 URI Review OSRO effectiveness on MCC switch issue

50-341/97003-09 NCV Inadequate post-modification testing for EDG logic

50-341/97003 10 IFl NRR review of EECW design issues

50-341/97003-11 URI RPS response time testing TS compliance

50-341/97003-12 URI Release of contaminated components from RRA

j 50-341/97003-13 VIO Failure to obtain a briefing of radiological work area conditions

50-341/97003-14 IFl Corrective actions for prompt NRC access 1

50-341/97003-15 IFl Review temporary background check controls l

Closed

l

50-341/97002-04 URI Review of MOV motor pinion gear inspection results I

i

.

!

f

40

,

,

.

o

e

Discussed

50 341/96016-04 IFl Protection of Equipment During Maintenance inside

Containment

50-341/96016-07 URI Condensate Storage Tank freeze protection

.

,

1

4

i

a

5

1

4

i

e

i

i

s

1

1

1

!

I

i

l

5

1

8

.

!

>

'

41

l

>

i

!

. - _ _ _ _ . _ . _ _ , _ ~ . . _ _ _ _ _ _ . . . . _ _ _ _ _ _ _ . _ .

_. _. _ _ _ _ . __ . . _ _ _ . _

,

k

,. ,

,

LIST OF ACRONYMS USED

'

CCHVAC Control Center Heating, Ventilation and Air Conditioning System

DER Deviation Event Report

, EDG Emergency Diesel Generator

EDP Engineering Design Package

! ECCS Emergency Core Cooling System

EECW Emergency Equipment Cooling Water

i FME Foreign Material Exclusion

GSW General Service Water

HELB High Energy Line Break

'

HPCI High Pressure Coolant injection

ICV Individual Cell Voltage

IEEE institute of Electrical and Electronic Engineers

"

IFl Inspection Followup Item

J LER Licensee Event Report

MCC Motor Control Center

MOV Motor Operated Valves

NCV Non-cited Violation

,

NSS Nuclear Shift Supervisor

NRR Nuclear Reactnr Regulation

'

i PASS Post Accident Sampling System

PCIV Primary Containment isolation Valves

PMT Post Maintenance Testing

, RBCCW Reactor Building Closed Cooling Water System

,

RBHVAC Reactor Building Heating Ventilation and Air Conditioning

l RCIC Reactor Coolant isolation System

,

RHR Residual Heat Removal

f RP Radiation Protection

RPS Reactor Protection System

'

RRA Radiologically Restricted Area

l RTV Room Temperature Vulcanizer

RWP Radiological Work Permit

'

SAC Station Air Compressor

SBGT Standby Gas Treatment System

I

SOP System Operating Procedure

TRM Technical Requirements Manual

i TS Technical Specification

, UFSAR Updated Final Safety Analysis Report i

URI Unresolved item

VIO Violation

WR Work Request

4

$

l

.

42

'. 1

i I

. . -

-_