ML20151X846

Insp Rept 50-341/88-07 on 880307-25.Violation & Deviation Noted.Major Areas Inspected:Maint Activities & Licensee Action on Previous Inspector Identified Problems

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: ML20151X807 ML20151X825 ML20151X836 ML20151X846
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: T. . arter 4- d l- 5 8

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Maintenance and Outages Section Date

Inspection Summary

, Inspection on March 7-25, 1988 (Report No. 50-341/88007(DRS))

Areas Inspected: Routine, announced inspection of maintenance activities and

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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

(Paragraphs 3.2.1.1 through 3.2.1.4). One deviation was also identified

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(Paragraph 2.1).

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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,

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. ,

The licensee's response to this violation included an evaluation that

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resulted, in part, in the identification of 757 safety significant,

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 ,

the LLRT outage, the licensee decided to not perform 137 of the 757 '

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

o istification 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

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objective evidence that the tests had ever been performed; in fact, the

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-

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related and important to safety. "A" PMs were to be performed as

, scheduled or an evaluation and justification required for rescheduling

while "B" category PMs reouire justification to be performed. This

, practice could preclude performance of most "B" PMs and appeared to the

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

l report (DER) is written, or if rescheduled an impact evaluation and

l justification for rescheduling must be comp %ted. The inspectors

reviewed a number of completed evaluation and justification forms

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and considered some to be inadequate. Licensee personnel were

i reevaluating these based on the inspectors comments.

( The inspactors reviewed several justifications for rescheduling "A"

l events that were completed in the Fall of 1987 and February 1988.

l_ The inspectors determined that most of the justifications were minimally

, adequate; some lacked firm technical bases for the conclusions reached.

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Procedure P0M 12.000.017(SQ), Revision 8, included an improved "PM

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

l 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

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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;

! however, the licensee noted some apparent mis-classification of

priority "A" items as "B" items. A re-review of those "B" items in

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safety-related systems has been completed. Other priority "B" items

will be re-reviewed for possible mis-classification when due for work

i 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

l package No. 639499. A QA surveillance, No. 5-QA-87-0654, was conducted

September 28, 1987, which included work request package No. 639499.

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A number of minor problems were identified with this package, by QA

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

l 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

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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

! determine if maintenance was accomplished, effective, and self assessed,

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The inspection was performed to coincide with a planned outage. The

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.

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

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of the poppet for Valve B2103F0228, the inspector noted that dimensions,

l 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

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neither the work package nor the procedure, POM 35.000.032(SQ),

i "MSIV - Assembly, Disassembly, Repair and Adjustment," Revision 8,

contained the ccceptance criteria or the required dimensions.

After this concern was discussed with licensee management, the

i inspection and machining of the MSIV poppets were stopped.

i The dimensions and tolerances were formally clarified by the

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manufacturer and the procedure was revised to include that

information. Failure to provide necessary dimensions,

j tolerances, and acceptance criteria in the procedure or

i work package and performance of work not specified in the

i work package is an example of a violation of 10 CFR 50,

j Appendix B, Criterion V, (341/88007-03A).

3.2.1.2 During work on emergency diesel generator (EDG)-13 according to

I 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 -

u' Engine General Maintenance," Revision 6, included instructions for

the removal and installation of fuel injector pumps; however, the '

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 '

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

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the outlet, the high point, read 50 psi, it was not obvious that the

jacket water system had not exceeded the 50 psig maximum.

In addition, the mechanic installed an extra gauge, not required in

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the procedure, on the blanked off flange, down stream of the jacket

' water heat exchanger. The purpose of this, as explained by the

mechanic, was for his "own piece of mind." The mechanic stated

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

j heat exchanger.

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l, who performed a technical evaluation and determined that no damage

I was caused to the EDG jacket water system, which could withstand

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

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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 ,

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 i

breakers of the residual heat removal (RHR) system. The work ,

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:

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 i

of the breaker maintenance;

The post maintenance test section was inaccurate; f

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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