ML20151X846
| ML20151X846 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/21/1988 |
| From: | Ted Carter, Jablonski F, Reynolds S, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151X811 | List: |
| References | |
| 50-341-88-07, 50-341-88-7, NUDOCS 8805040267 | |
| Download: ML20151X846 (10) | |
See also: IR 05000341/1988007
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/88007
Docket No. 50-341
License No. NPF 43
Licensee: The Detroit Edison Company
2000 Second Avenue
Detroit, MI 48224
Facility Name:
Fermi 2
Inspection At: Monroe, MI
Inspection Conducted: March 7-25, 1988
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Inspectors:
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Approved By:
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Maintenance and Outages Section
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Inspection Summary
Inspection on March 7-25, 1988 (Report No. 50-341/88007(DRS))
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Areas Inspected: Routine, announced inspection of maintenance activities and
licensee's action on previous inspector-identified problems. The inspection
was conducted during a planned outage utilizing selected portions of Inspection
Procedures 62700, 62702, 92701, and 92702.
Results:
In the areas inspected, one violation was identified including four
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specific examples of inadequate proccderes or failure to follow procedures
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(Paragraphs 3.2.1.1 through 3.2.1.4).
One deviation was also identified
(Paragraph 2.1).
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8805040267 880422
ADOCK 05000341
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DETAILS
1.
Persons Contacted
Detroit Edison Company
B. Sylvia, Group Vice President
- P. Anthony, Compliance
- D. Gipson, Plant Manager
- L. Goodman, Supervisor, Licensing
Z. Lenart, General-Director, Nuclear Engineering
R. Lightfoot, Support Supervisor, Maintenance
- R. May, Superintendent, Maintenance and Modifications
W. Orser, Vice President, Nuclear Operations
- R. Stafford, Director, Quality Assurance
- B. Wickman, Coordinator, Preventive Maintenance
- Indicates those personnel who atterded the exit meeting on March 25,
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1988.
Other persons were contacted as a matter of routine during the inspection.
2.
Licensee Action on Previous Inspection Findings
2.1 (0 pen) Violation (341/87028-01):
Failure to perform preventive
maintenance (PM).
Licensee action to resolve this issue is described in
the licensee's response dated November 13, 1987, and the supplemental
response dated December 30, 1987.
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The licensee's response to this violation included an evaluation that
resulted, in part, in the identification of 757 safety significant,
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Priority A activities that had not been previously completed either
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through the PM Program or through other maintenance tasks. The licensee
committed to have all of these activities completed no later than prior
to startup following the LLRT outage (April 15,1988).
Prior to entering
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the LLRT outage, the licensee decided to not perform 137 of the 757
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backlogged PM activities,'but to reschedule the activities for future
refueling outages.
These activities include 4160V, 480V, and MCC breakers.
The licensee provided the inspectors in February 1988 with correspondence
between engineering and maintenance that was meant to provide the technical
oistification for not completing the 137 PM activities as scheduled.
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After discussions between the inspectors and licensee personnel from
engineering and maintenance, it was determined that the justification
provided by engineering to maintenance did not provide an adequate
technical evaluation for rescheduling the PMs.
The inspectors were
concerned that the Engineering Department did not provide the Maintenance
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Department the level of quality engineering support and interaction
necessary to effect a highly efficient working unit.
The licensee
agreed to reevaluate the PM activities and either perform the activities
prior to startup following the LLRT outage or provide complete and
accurate technical evaluations that clearly supported rescheduling the
PM activities with no adverse affects on reliability and operability.
This is an open item pending performance of the PM activities or review
of the technical justification.
(341/88007-1).
In conjunction with the above, during review of PM activities on breakers,
the inspectors noted that the Updated Final Safety Analysis Report (UFSAR),
Section 8.3.1.1.13.1., required breaker operating tests and protective relay
tests to be conducted initially, one year thereafter, and from then on
coincident with reactor shutdown.
The licensee could not provide any
objective evidence that the tests had ever been performed; in fact, the
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licensee's regulatory commitment tracking system indicated that the
tests were to be covered by the PM program but the program shows
that the tests were never completed.
This is a deviation from UFSAR,
Section 8.3.1.1.13.1 (341/88007-2).
The inspectors reviewed the current PM program described in Revision 8
of P0M 12.000.017(SQ) "Preventive Maintenance Program," which was issued
for use March 7, 1988.
Revision 7 of the procedure was also reviewed.
Considerable management attention appeared to have been provided in the
PM area and substantial improvement from inspection 50-431/870028 was
evident. Both Revisions 7 and 8 of P0M 12.000.017(S0) required that PM
items be divided into "A" or "B" categories with "A" including safety-
related and important to safety.
"A" PMs were to be performed as
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scheduled or an evaluation and justification required for rescheduling
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while "B" category PMs reouire justification to be performed. This
practice could preclude performance of most "B" PMs and appeared to the
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inspectors as a poor way to maintain material condition of the plant.
Considerable emphasis has been placed on the performance of priority
"A" PMs.
If not performed as scheduled a deficiency evaluation
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report (DER) is written, or if rescheduled an impact evaluation and
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justification for rescheduling must be comp %ted.
The inspectors
reviewed a number of completed evaluation and justification forms
and considered some to be inadequate.
Licensee personnel were
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reevaluating these based on the inspectors comments.
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The inspactors reviewed several justifications for rescheduling "A"
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events that were completed in the Fall of 1987 and February 1988.
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The inspectors determined that most of the justifications were minimally
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adequate; some lacked firm technical bases for the conclusions reached.
Procedure P0M 12.000.017(SQ), Revision 8, included an improved "PM
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Justification Form" and a new guideline with questions that should be
taken into consideration when rescheduling a PM event.
The improved
form and new guideline should aid in improving the technical content
and supporting cualuation that is needed to reschedule a PM event.
PM justification will be reviewed in the future for significant
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improvement in technical content and supportive bases.
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Although implementation of the PM program was improved, additional effort
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implementa tion. This item will remain open for additional review during
a subsequent inspection.
2.2 (0 pen) Unresolved Item (341/87028-03): Possible inadequacy of the overall
scope of the PM program.
The inspectors reviewed current action taken to
verify or determine the adequacy of the scope of the PM program as follows:
2.2.1
Current PM program requirements were compared with vendor
recommendations.
Licensee personnel stated that, in each case where
the respective PM event differs from the vendor recommendations, a
technical evaluation will be performed and PM events will be added
or adjusted as necessary. The inspectors were not provided with a
scheduled completion date for this activity.
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2.2.2
A review of PM events about importance to plant safety was completed;
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however, the licensee noted some apparent mis-classification of
priority "A" items as "B" items. A re-review of those "B" items in
safety-related systems has been completed.
Other priority "B"
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will be re-reviewed for possible mis-classification when due for work
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on the periodic PM schedule.
If classified as
"A," the PM activity
will be completed at that time.
2.2.3
There is continuing review of PM events as the PMs are scheduled for
work to combine events where possible, adjust periods as necessary
and eliminate errors.
This will improve efficiency, utilization of
manpower, and system outage time,
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This item remains open until completion of Items 2.2.1 and 2.2.3.
2.3 (Closed) Unresolved Item (341/87028-05):
Confusing and inadequate work
instructions and poor documentation of work performed in work request
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package No. 639499. A QA surveillance, No. 5-QA-87-0654, was conducted
September 28, 1987, which included work request package No. 639499.
A number of minor problems were identified with this package, by QA
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including inadequate work instructions. As described in Paragraph 3.2.1
of this report, a number of problems with confusing and inadequate work
procedures were noted during this inspection and a violation was
prepared; therefore, this item is closed and the concern will be
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followed under violation No. 88007-03. This item is closed.
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2.4 (Closed) Violation (341/87028-081:
Failure of QA auditors to determine
adequacy and ef thtiveness of Q_A program implementation. Licensee action
to resolve this issue is described in the licensee's response dated
November 13, 1987.
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The inspector reviewed Nuclear Quality Assurance Procedure 1801, "Audits,"
Revision 8, which now requires that:
Audit checklist items be designated as'"high" or "low" priority, and
high priority items must be performed during the audit;
Audit checklist be reviewed by the audit team leader prior to the
audit;
The audit team leader perform a post audit review of the checklists
to verify that checklist items have been adequately addressed.
Adequate justification must be provided for any items not audited.
The inspector reviewed all records for three audits conducted since
the changes to the procedure were made, and completed checklists for two
additional audits. The audits appeared to be adequate and complete. All
checklist items were noted having been performed. Checklists appeared to
be objective and performance oriented.
This item is closed.
2.5 (Closed) Violation (341/87028-09A): Audits of unit activities, such as
operations, corrective action, and fire protection were not performed
within specified frequencies of Fermi 2 Technical Specification, Section 6.5.2.8.
Licensee action to resolve this issue is described in
the licensee's response dated November 13, 1987. The inspector reviewed
the current audit schedule and noted this requirement had been included.
The inspector also reviewed the scheduled "Corrective Action" audit and
noted that it was complete.
This item is closed,
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One deviation was identified (2.1).
3.
Evaluation of Maintenance
This inspection was conducted to evaluate activities at Fermi 2 to
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determine if maintenance was accomplished, effective, and self assessed,
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The inspection was performed to coincide with a planned outage. The
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evaluation was accomplished by:
Review of completed work requests and other records
Review of Preventive Maintenance tracking methods and controls
Observation of work activities
Management involvement in assuring quality and the quality verification
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process were also reviewed.
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3.1 Accomplishment of Maintenance
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3.1.1
Preventive Maintenance (PM)
Complete discussion of PM is included in Section 2.1 of this report
as a follow-up to violation 431/87028-01.
3.2 Effectiveness of Maintenance
3.2.1
Observation of Work-
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During this inspection maintenance work in progress was observed in
four areas. As discussed below, based on observations by the inspectors
early in the inspection the licensee temporarily stopped all outage
related work to impress upon workers the importance of following
procedures.
Work included repair of the main steam isolation valves (MSIV),
inspection and repair of the engines for the emergency diesel
operated generators, motor operated valve (MOV) repair, M0 VATS
testing, and electrical breaker maintenance. The following observations
were made.
3.2.1.1
Main Steam Isolation Valves (MSIVs)
Rework of the MSIVs was necessary due to the failure of the valves
to pass local leak rate testing (LLRT).
Both inboard and outboard
MSIVs were disassembled and reworked to reduce leakage through both
the main and pilot seating surfaces. The inspector reviewed work
being performed on Valves B2103F022A (WR No. 0248012788), 82103F022
(WRNo.0218012788),B2103F022B(WRNo.0238012788),and82103F022C
(WR.No. 0228012788). While observing the inspection of the main seat
of the poppet for Valve B2103F0228, the inspector noted that dimensions,
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tolerances, and acceptance criteria were provided orally by the valve
vendor representative.
Discussions with licensee personnel, including
the QC inspector, failed to identify the source documents to verify
validity of the information. The seat surface was determined to be
unacceptable and a decision was made to machine the seat.
In a
subsequent review of the work package, the inspector noted that
neither the work package nor the procedure, POM 35.000.032(SQ),
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"MSIV - Assembly, Disassembly, Repair and Adjustment," Revision 8,
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contained the ccceptance criteria or the required dimensions.
After this concern was discussed with licensee management, the
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inspection and machining of the MSIV poppets were stopped.
The dimensions and tolerances were formally clarified by the
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manufacturer and the procedure was revised to include that
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information.
Failure to provide necessary dimensions,
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tolerances, and acceptance criteria in the procedure or
work package and performance of work not specified in the
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work package is an example of a violation of 10 CFR 50,
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Appendix B, Criterion V, (341/88007-03A).
3.2.1.2
During work on emergency diesel generator (EDG)-13 according to
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work requests No. W848880125 and P.156880219, inspectors observed
installation of the No. 7 opposite control side fuel injector
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pump.
Procedure POM 35.000.052(SR), "Emergency Diesel Generator -
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Engine General Maintenance," Revision 6, included instructions for
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the removal and installation of fuel injector pumps; however, the
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procedure was not und by maintenance personnel.
Instead, mechanical
work and inspection were performed in accordance with verbal
instructions from the vendor representative. The fuel injector pump
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was specifically removed in order to inspect the cam roller for
possible damage because of wear indications on the cam shaft. After
the inspector informed licensee personnel the indications were
documented on Deviation Event Report (DER) 88-0403; however, removal
and installation of the injector pump without use of procedures and
results of the cam roller inspection were not documented.
Accomplishing work without use of appropriate instructions and
inspecting without acceptance criteria is an example of a violation
of 10 CFR 50, Appendix B, Criterion V (341/88007-38).
3.2.1.3
The inspectors observed pressure testing of the EDG-13 jacket water
system.
Procedure P0M 34.000.14(5Q), "Emergency Diesel Generators -
Inspection," Revision 8, Step 7.3.4 required a hydrostatic test of the
jacket water system to 50 psig, by using a hydrostatic test pump.
The procedure contained a "CAUTI0fi" not to exceed 50 psig in the
jacket water headers.
Instead of using a hydrostatic pump a
hose was connected from the jacket water system to the RHR demineralized
water header drain valve P11F213 along with a pressure gauge and two
relief valves connected to the outlet, the high point.
In order for
the gauge to maintain a 50 psi reading, water was allowed to run out
of both relief valves. (The P11 system pressure normally exceeds 70
psig and could exceed 100 psig).
Even though the pressure gauge at
the outlet, the high point, read 50 psi, it was not obvious that the
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jacket water system had not exceeded the 50 psig maximum.
In addition, the mechanic installed an extra gauge, not required in
the procedure, on the blanked off flange, down stream of the jacket
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water heat exchanger. The purpose of this, as explained by the
mechanic, was for his "own piece of mind." The mechanic stated
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that it wasn't in the procedure to install the extra gauge but he
decided to install it to refute the engineer's assertion that there
would be a 8 psid between the inlet and outlet of the jacket water
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heat exchanger.
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The inspectors discussed this apparent problem with the licensee,
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who performed a technical evaluation and determined that no damage
was caused to the EDG jacket water system, which could withstand
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100 psig.
Installation of the extra gauge did not materially affect
or invalidate the test and results of determining the existence of
jacket water cooling leakage in the diesel generator.
Failure to accomplish work in accordance with documented procedures is
another example of a violation of 10 CFR 50, Appendix B, Criterion V
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(341/88007-3C).
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3.2.1.4
While observing work on the diesels, the inspector noted that work
had stopped on the replacement of broken fuse holders on the control
panel for EDG-13. The inspector noted that the fuse holders were
declared "like for like" replacements, therefore work was completed
as routine maintenance even though the replacement fuse holders were
of a different size, made of a different material, and required
drilling of two additional holes for mounting.
This item was discussed with licensee personnel who told the inspector
that this installation was not considered a modification because the
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supplier listed the same part numbers for the original and replacement
fuse holders. However, the inspector noted that procedure
NOIP 11.000.004(SQ), "Design Change Process," Revision 2, Enclosure A
stated that minor "changes to mounting details" is considered a minor
modification; therefore, the fuse holder replacement should have been
reviewed as a minor change rather than completed as routine
maintenance. A letter was issued on March 24, 1988, to all Nuclear
Engineering Personnel clarifying the precise definition of a
modification.
Failure to properly classify the changes required for this fuse holder
replacement as a modification as required by procedure is another
example of a violation of 10 CFR 50, Appendix B, Criterion V
(341/88007-03D).
3.2.1.5
The inspector observed maintenance associated with 480V circuit
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breakers of the residual heat removal (RHR) system.
The work
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was performed using Maintenance Instruction - M030, "ITE Circuit
Breaker Type K-6005 - General Maintenance." While observing the
work, the inspector noted several concerns as follows:
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Numerous changes were made to the procedure during the
performance of work;
Several days were taken to complete a job that should have
taken several hours;
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There appeared to have been limited training in performance
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of the breaker maintenance;
The post maintenance test section was inaccurate;
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Attachment "A" to the post maintenance test section did not
exist;
After two successive failures of a pressure test to the trip
bar, the third test, which was successful, was accepted without
question;
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Supervision was lacking.
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One technician on loan to the Fermi site, who specialized in PM of
breakers was not familiar with the Fermi 2 Maintenance Instruction.
The technician followed the instruction but because of the many
changes made during the job, work was stopped because supervision
was not readily available.
The inspector concluded that poor
preplanning of the work and inadequate walk through of the work
process summarized the problems which occurred during the work.
The apparent inadequacy of maintenance procedures 6 an open item
and will be reviewed during a subsequent inspectf on (;41/88007-04).
One violation was identified.
3.3 Quality Verification
Tha inspector reviewed the audit of Preventive Maintenance conducted in
November and December of 1987 as well as several other recent audits.
Details of this review are included in Section 2.4. of this report.
No violations were identified.
3.4 Conclusion
The inspection team concluded that the accomplishment, effectiveness and
self assessment of maintenance were accomplished but at a minimum level
based on the following:
Management involvement and emphasis is needed to correct what
appeared to be a casual approach to following procedures and
abdicating responsibility to vendor representatives for
maintenance activities.
Management involvement appeared to be improving in providing
adequate attention to maintenance areas; however, availability
and involvement of first line supervision during work activity
must significantly improve.
Procedures were not adequately reviewed and validated before
use which caused significant delays in completing routine
maintenance activities.
The Engineering Department did not provide the Maintenance
Department a level of quality engineering support and
interaction to assure efficient and effective use of
resources, including the methods used to evaluate and
justify deferrals of preventive maintenance.
4.
Open Items
Open items are matters that have been discussed with the licensee, which
will be reviewed further by the inspector and involve some action on the
part of the NRC or the licensee or both. Two open items disclosed during
this inspection are presented in Paragraphs 2.1 and 3.2.1.5.
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5.
Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
on March 25, 1988, and sumarized the purpose, scope, and findings of the
inspection. This inspectors discussed the likely informational content
of the inspection rt.'rt with regard to documents or processes reviewed
by the inspectors during the inspection. The licensee did not identify
any such documents or processes as proprietary.
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