ML20217K282
| ML20217K282 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/31/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217K250 | List: |
| References | |
| 50-341-98-04, 50-341-98-4, NUDOCS 9804070185 | |
| Download: ML20217K282 (17) | |
See also: IR 05000341/1998004
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U.S. NUCLEAR REGULATORY COMMISSION
REGIONlli
Docket No:
50-341
License No:
Report No:
50-341/98004(DRP)
Licensee:
Detroit Edison Company (DECO)
Facility:
Enrico Fermi, Unit 2
Location:
6400 N. Dixie Hwy.
Newport, MI 48166
Dates:
November 13,1997, through February 26,1998
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inspector:
C. O'Keefe, Resident Inspector
Approved by:
Bruce Burgess, Chief
Reactor Projects Branch 6
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9004070185 980331
ADOCK 05000341
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EXECUTIVE SUMMARY
. Enrico Fermi, Unit 2
NRC Special Inspection Report No. 50-341/98004(DRP)
This inspection covered aspects of licensee inspection of failed irradiated fuel, as well as other
fuelinspections for possible debris, and related activities. The design basis and licensing basis
for the fuel handling and storage system was reviewed. - Two violations and one deviation were -
identified.
Operations
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The inspector concluded that operators were unfamiliar with the prerequisites required to
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be performed prior to granting permission to move fuel and conduct fuel inspection
activities. This appeared to be due primarily to a lack of administrative control and
documentation. In addition, control room operators were not as involved in the
movement and inspection of fuel as they would be during refueling activities.
(Section O1.1)
Operators did not question the practice of storing fuel in the fuel preparation machine
(FPM) ovemight, even though this practice was not specified in the goveming work
request or discussed during shift briefings. When the inspector questioned the practice,
the nuclear shift supervisor acted conservatively to place the bundle in question back in
the normal storage rack until the issue could be further evaluated. The licensee intended
to store fuel ovemight in the FPM, but did not document the intent, did not brief it during
the shift briefing with plant operators, and did not evaluate the acceptability of storage of
spent fuel in the FPM prior to its use. A deviation from a regulatory commitment was
identified. (Section O1.2)
The complex evolution involving fuel inspection was performed without an appropriate
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level of administrative controls. The work request used to control the evolution was
inappropriate to the circumstances for which a violation was issued. The inspectors
concluded that the limitations of using a work request contributed to unclear roles and
responsibilities for operators and other supervisory personnel. Licensee corrective
actions for this problem were appropriate and comprehensive. (Section 03.1)
Enoineerina
The inspector concluded that the licensee did not analyze far or implement adequate
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criticality controls for fuel bundle disassembly and handling of multiple fuel rods
simultaneously, which was considered a violation. The condition was briefly considered
and dispositioned informally without using any documented analysis, since none was
available onsite. Subsequent analyses demonstrated that no potentially critical
configuration existed. . However, the first of these analyses was not available for more '
- than a month after the fuel inspection. (Section E3.1)
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The inspector identified a lack of formal design control measures and documentation for
the FPM's upper travel limit and radiation monitor interlock. No regulatory requirements
. were violated. (Section E3.2)
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. The inspector concluded that the licensee had an informal training and qualification
process with respect to refueling and associated work tasks. No specific deficiencies
related to training activities were identified and workers were observed to be
knowledgeablw of the work activities. However, knowledge weaknesses were noted in
emergency response to a fuel handling mishap. (Section ES.1)
Plant Support
The inspector observed that radiation protection personnel were closely involved in all
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phases of the preparation and execution of the fuelinspections. Workers were obscrved
to follow good radiation worker practices. The inspectors observed goed foreign material -
controls and tool accountability during the work. (Section R1.1)
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Report Details
Summary of Plant Status
This inspection covered fuel inspections conducted over the period of November 13-19,1997,
and subsequent licensee response to NRC concems. The plant was operating near 96 percent
power during the fuelinspections. The fuelinspections were intended to locate and determine -
the cause for two failed fuel bundles, retrieve foreign material from a previously inspected bundle
for source determination,' and visually inspect 24 bundles for the presence of foreign material.
1. Operations
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' Conduct of Operations
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01.1
Conduct of the Irradiated Fuel Inspection and Operations' involvement
a.
Inspection Scope (86700. 71707)
The inspector used Inspection Procedures 86700 and 71707 to evaluated the adequacy
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of the licensee's spent fuel handling activities and to determine whether or not these
activities were in t,onformance with the Technical Specifications (TS) and applicable
regulations. The inspector reviewed operator logs, surveillance test documentation,
applicable administrative procedures, fuel inspection procedures and work requests. ' The
briefing notes used to brief operators prior to beginning the inspection were reviewed with
the licensee supervisor. Inspection findings were discussed with a nuclear shift
supervisor (NSS) and the Operations Superintendent.
b.
Observations and Findinas
The inspector identified that the licensee did not have an administrative procedure that
applied to fuel handling during plant power operations. Because the reactor was
operating at high power, plant conditions were significantly different from those that would
exist during a refueling outage. Thus, the only existing administrative procedure, MOP 13,
" Conduct of Refueling and Core Alterations," normally intended for a refueling outage,
was not utilized by the licensee. Instead, the fuel inspection activities were conducted
using a work request.
The inspector noted that after the first day of fuel inspections, the control room logs did
not contain entries that documented the granting and removal of permission to conduct
fuel movement and inspections in the spent fuel pool. Also, the control room log did not
document the verification _ of prerequisites or other related information normally required to
i conduct any safety related procedure. These types of log entries were observed during
~ the previous two refueling activities. The inspector discussed the lack of log entries and
documentation with _ supervisory personnel from operations and reactor engineering, and -
logs of the work status were subsequently kept.-
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Technical Specifications did not directly address fuel handling outside a refueling outage.
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The inspector attempted to determine what controls were being used by questioning the
Nuclear Assistant Shift Supervisor to determine what equipment was verified to be
operable prior to granting permission to start. The Nuclear Assistant Shift Supervisor
replied that it was unclear what equipment was supposed to be available. The inspector
determined that the lack of clarity was because
The applicable work request (000Z975403) was not present in the control room for
operators to review (only one official copy of a work request was allowed to exist).
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The work request specified some prerequisites directly and many indirectly by
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specifying performance of numerous procedures (also not available in the
control room).
The work request did not clearly define which prerequisites were required to be
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completed prior to granting permission to move or inspect fuel, or which were
required to be reverified daily.
No narrative log was kept on the refueling floor to document verifications and work
performed. The inspector was eventually able to determine what prerequisites were
specified for the work. All appropriate prerequisites and pre-use checks were determined
by the inspector to have been met, but few were documented.
The inspector verified that control room operators were kept informed of fuel movements,
and that a status board of fuellocations was kept current in the control room. However,
the inspector noted that operations personnel were not directly participating in the fuel
handling and inspection activities, and did not discuss the status of the work during shift
tumover briefings. Operators appeared to have minimalinvolvement in the evolution. As
further discussed in Section 01.2, operators maintained the fuel status board updated
without recognizing or questioning that fuel was left overnight in the fuel preparation
machine. This contrasted significantly with practices observed during the previous two
refueling operations.
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The inspector noted that the task manager was acting as a supervisor for the contractors
and was actually performing tasks including fuel inspections, recording equipment
entering the tool control area, enforcing foreign material control practices, and acting as
spotter for fuel bundle movements. The inspector noted that the assignment of multiple
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responsibilities limited the effectiveness of supervisory oversight.
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c.
Conclusions
The inspector concluded operators were unfamiliar with the prerequisites required to be
performed prior to granting permission to move fuel and conduct fuel inspection activities.
This appeared to be due primarily to a lack of administrative control and documentation.
In addition, control room operators were not as involved in the movement and inspection
of fuel as they would be during refueling activities.
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01.2 Temoorary Storaae of Fuel Without Adecuate Analysis and inadeouste Confiouration
Control
a.
Inspection Scope (86700)
The inspector identified that irradiated fuel was being stored ovemight in the fuel
preparation machine, and questioned the basis for this practice with the NSS and task
manager for the work. Licensing basis documents, seismic qualification documentation,
and system prints were reviewed and discussed with applicable members of the
licensee's staff,
b.
Observations and Findinas
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b.1
. Temporary Fuel Storage
The inspector identified on November 17,1997, at the conclusion of work activities for the
day, that a fuel bundle remained in the fuel preparation machine (FPM). The FPM is an
air-operated, chain-driven fuel bundle elevator mounted to the side of the spent fuel pool.
A worker stated that a fuel bundle was stored overnight in the FPM to facilitate the prompt
start of work the next day. This same practice had been used overnight on
November 14 - 15,1997, and again over the weekend November 15 - 17. The inspector -
determined that the storage of spent fuel in the FPM was not briefed with either the
operators or the contractors, nor was it documented in the work request. Also, licensee
senior management was unaware of this practice. The NSS was not aware that fuel was
being stored in this manner, even though control room operators had been updating the
fuel status board.
The inspector questioned whether the storage of irradiated fuel in the FPM while
unattended was reviewed and approved. The licensee had no list of approved storage
locations for nuclear fuel. In response to the inspector's question, the NSS ordered the
bundle retumed to the spent fuel pool storage rack on November 17 until the issue could
be clarified. The inspector identified that Procedure 23.710, " Fuel Handling System,"
Revision 25, Precaution 3.7.4, stated " Fuel in Spent Fuel Pool shall only be stored in
storage cells designed for fuel storage." This did not appear to be met when storing fuel
in the FPM. However, as the above statement is only a precaution in the procedure, this
was not considered to be an adequate basis for a violation. To assess the suitability of
using the FPM as a storage location, the inspector questioned whether the seismic
analysis for the FPM bounded the configuration existing during the observed storage
periods, and whether adequate water shielding was available above the bundle.
b.2
Seismic Qualification Documentation
Table 3.7-15 of the Updated Final Safety Analysis Report (UFSAR) listed the FPM as
seismically qualified, with no amplifying information provided. The inspector questioned
whether the configuration assumed in the analysis bounded the configuration used during
the fuelinspection and storage of irradiated fuel. The following fixtures were deterrnined
- to have been attached to the FPM for the fuel inspection:
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a lower rotating inspection fixture
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an upper rotating inspection fixture
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a non-destructive examination fixture for an individual fuel rod
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The attachments were installed by vendor personnel but not clearly documented When
- the inspector questioned what attachments had been added to the FPM, the nuclear fuels
group requested that vendor personnel provide the information from memory due to lack-
of documentation.
The licensee evaluated for a two month period the basis for reporting the FPM as
seismically qualified in the UFSAR. The licensee was originally unable to locate a report
from the vendor, contracted to complete an analysis, and stated that a seismic analysis
had been completed and was acceptable. Based on discussions with the vendor, the
licensee was able to determine that the analysis had been performed. Once the analysis
was received, . engineering personnel concluded that the analysis provided a sufficient
margin to bound the extra weight added to the fuel preparation machine at the time of the
inspection. However, cognizant engineering personnel were unaware of the limitations of
the analysis and had not considered the potential impact caused by adding inspection
fixtures to the fuel preparation machine prior to making the configuration changes. This
was considered to be indicative of a weak understanding of the design and licensing
basis for the fuel handling system and poor configuration control and documentation.
Violations involving 10 CFR 50.59 and 10 CFR 50, Appendix B, Criterion ill were
consiliered. However, because the original seismic analysis bounded the actual as
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found configuration, the technical and regulatory significance of these issues were
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considered to be minimal.
b.3
Available Water Depth
The inspector questioned whether the TS 3.9.9 requirement to maintain at least 22 feet of
water over the top of irradiated fuel assemblies had been met when irradiated fuel had
been stored ovemight and over the weekend in the FPM. This TS was specific to fuel
stored in the spent fuel pool racks, but the intent clearly applied to fuel storage in general.
As configured, the licensee estimated that a bundle stored in the FPM in the fully down
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position had only about 20.5 feet of water on top. Regulatory Guide 1.25, " Assumptions
Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident
in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors,"
specified assumptions to be used for analyzing potential fuel handling mishaps, and
specified_23 feet of water to absorb fission product gases. This discrepancy was not
. recognized or analyzed by the licensee. This was determined to be a deviation from the
UFSAR commitment to Regulatory Guide 1.25. (DEV)(50-341/98004-01)
In response to this issue, the licensee committed to evaluate the applicable conditions
required to store spent fuel with the intent of specifying approved fuel storage locations.
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c.
Conclusions
Operators did not question the practice of storing fuel in the FPM ovemight, even though
this practice was not specified in the goveming work request or discussed during shift
briefings. When the inspector questioned the practice, the NSS acted conservatively to
place the bundle in question back in the normal storage rack until the issue could be
further evaluated. The licensee intended to store fuel ovemight in the FPM, but did not
document the intent, did not brief it during the shift briefing with plant operators, and did
not evaluate the acceptability of storage of spent fuelin the FPM prior to its use. A
deviation from a regulatory commitment was identified.
O3
Operations Procedures and Documentation
O3.1
Inadeauate Administrative Controls for Handlina irradiated Fuel
a.
Inspection Scope (71707. 86700. 62707)
The inspector investigated the administrative controls being used to control the complex
job of inspecting multiple fuel bundles. Work requests, task procedures, and briefing
notes for the fuel inspection, as well as administrative procedures for refueling were
reviewed. The inspector interview 3d workers and operators associated with the evolution
to determine their understanding of the controls in place.
b.
Observations and Findinas
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The inspector identified that the licensee did not have a single administrative procedure
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goveming the handling of nuclear fuel when not in a refueling outage. Instead, the fuel
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inspections were performed under Work Request 000Z975403.
The work request was considered by the inspectors to be inadequate for administrative
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control of this complex evolution. The work request specified performance of a number of
procedural activities without adequately specifying the work scope or sequence of the
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work. This document did not adequately specify administrative controls, such as:
Prerequisite testing prior to using the refueling bridge for moving fuel.
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Preventive maintenance and surveillance testing for all necessary equipment.
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Minimum work group manning and supervisory oversight.
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Narrative log keeping requirements.
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Prerequisites were dispersed throughout several procedures, and the procedures
were not available for operators when permission was requested to start fuel
inspections each day.
The work request assigned responsibility for the evolution only to the Refuel Floor
Coordinator (RFC). The inspector determined that no RFC was formally assigned
to the job, and that the actual supervisor was not qualified as an RFC.
By using a work request, the level of rnanagement review for this work was minimal. The
inspector noted that the licensee had performed similar irradiated fuel inspections in
June 1997. In preparing for the June 1997 fuel inspections, the licensee formally
screened the job and concluded that it did not require the increased controls of an
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Infrequently Performed Test / Evolution because the personnelinvolved were experienced
due to a similarjob being performed in 1994. No formal screening was performed or
required for the November inspections, even though the fuel leak was an order of
magnitude larger than the previous fuel failures at the site.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings, of a type appropriate to
the circumstances. Work request 000Z975403 did not contain information required to
control the work scope and sequence associated with fuel inspection activities. Based on
the lack of appropriate work controls, work request 000Z975403 was considered to be an
instruction inappropriate to the circumstances, which was a violation of 10 CFR 50,
Appendix B, Criterion V. (VIO)(50-341/98004-02)
In response to the inspector's concerns, licensee senior management placed a
moratorium on all work activities in the refueling area until the issues were adequately
addressed. This action resulted in significantly delaying completion of the inspection of
bundle YJ7119. The licensee is in the process of creating a new administrative
procedure for controlling work activities in the refueling area that are performed with the
reactor at power. As part of this effort, a review team was created to perform a detailed
review of the work performed, procedure adequacy, documentation, and work practices
related to the fuel handling and storage system.
c.
Conclusions
This complex evolution was performed without an appropriate level of administrative
controls. The work request used to control the evolution was inappropriate to the
circumstances, which was a violation. The inspectors concluded that the limitations of
using a work request contributed to unclear roles and responsibilities for operators and
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supervisory personnel. Licensee corrective actions for this problem were appropriate and
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comprehensive.
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11. Enaineerina
E3
Enaineerina Procedures and Documentation
E3.1
Inadeauate Criticality Controls Durina Fuel Disassembly
a.
Inspection Scope (86700. 71750 )
The inspector observed portions of inspection activities for the two failed fuel bundles and
reviewed applicable procedures. One fuel rod was observed to have a 360-degree
circumferential crack and the licensee decided to remove adjacent rods to better observe
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the failure without disturbing it. The inspector reviewed available documentation for
criticality controls and discussed the issue with reactor engineering supervisory
personnel.
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b.
Observations and Findinas
During the inspec, tion of the bundle YJ7119, the initial visualinspection indicated a
360-degree circumferential crack at the bottom of inner fuel rod 85. The integrity of B5
was suspect, so adjacent fuel rods were removed to allow visual inspection of the
damaged rod. Up to four rods at a time were removed from the bundle, and were hung
individually from temporary hooks attached to the fuel pool railing.
The inspector was concemed that removing individual fuel rods from the known, safe
configuration of the fuel bundle could potentially result in a critical geometry. The
inspector identified that the licensee had not established specific controls to prevent
inadvertent criticality caused by changing the fuel geometry during removal of fuel rods
from a bundle. Also, the work package did not include steps to cover added controls for
removing more than one fuel rod at a time. Additionally, an analysis was not available
that delineated how many fuel rods could be safely located in the same vicinity during this
Work.
Reactor engineering personnel believed that the licensee-approved vendor procedures
provided for removing multiple fuel rods. The inspector pointed out that the procedures
did not prohibit such actions, but provided no guidance or limitations. One procedure,
246-GP-43, " Fuel Rod Accountability," provided an administrative tracking process to
ensure that fuel rods were replaced in their original location, but no storage or criticality
controls.
After the inspector raised the issue, the licensee obtained a letter from General Electric
stating that 14 rods from a GE11 bundle could be safely stored together. The inspector
subsequently identified that the licensee had only evaluated removing a single fuel rod at
a time (Safety Evaluation 89-0138).
The inspector determined that another contributing factor for this condition was the lack
of a clearwork scope definition. Station workers had recognized that because the work
scope had changed from removal of a single rod to multiple rods from a bundle, there
was a need to stop the work and consider how to safely proceed. The situation was
discussed with reactor engineering supervision. However, no one involved considered
that additional controls were appropriate to prevent a critical geometry, and a revisionto
the work package was not considered. Based on a brief, informal discussion on this
issue between the licensee and a vendor supervisor, the licensee concluded that
inadvertent criticality was not a concern based on engineering judgement. However,
neither applicable procedures nor other available documentation were referred to in
reaching this conclusion.
General Design Criterion 62 required that criticality in the fuel handling and storage
system be prevented by physical systems or processes, preferably by use of
geometrically safe confi0urations. The inspector determined that the contractors had two
styles of geometrically safe fuel rod storage racks available for the inspection, but had
recommended using the hooks to avoid the need to subsequently decontaminate the
racks. A lack of criticality controls during fuel bundle disassembly was considered a
violation of General Design Criterion 62 as described in the attached NOV.
(VIO)(50-341/98004-03)
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- The licensee was in the process of reviewing all fuel handling evolutions to determine
actual and appropriEte criticality controls. Corrective actions were not yet formulated at -
- the completion of this inspection.
c.
Conclusions -
The inspector concluded that the licensee did not analyze for or implement adequate
criticality controls for handling multiple fuel rods simultaneously, which was. considered a
violation of General Design Criterion 62. This potential for a critical configuration was
briefly considered and dispositioned informally without using any documented analysis, .
since none was available onsite. Subsequent analyses demonstrated that no potentially
critical configuration existed.
E3.2 : Inadeouste Control of Eauipment Desian Safety Features
a.
Inspection Scope ( 37551. 37700 )
The inspector noted that the vendor-supplied rotating inspection fixture used in the FPM
during this fuel inspection was placed under the bundle, resulting in the irradiated fuel
being six inches closer to the SFP surface. The inspector reviewed documentation to
determine if the six inch difference was appropriately evaluated. The inspector
questioned the fuel handler who had reset the chain stops. . The design basis for the
upper travel limit for the FPM was reviewed, including design change documents and
- safety evaluations,
b.
Observations and Findinas
The FPM was equipped with chain stops designed to prevent an irradiated bundle from
being raised too close to the surface of the spent fuel pool. This was intended to ensure
adequate shielding for personnel. The inspector noted that a GE document stated that a
special rotating inspection fixture would be supplied for the inspections. This fixture was
six inches thicker than the normal fixture, and would be placed under the bundle in the
FPM. This necessitated resetting the chain stops to account for the extra bundle height.
The UFSAR stated that the FPM's full upward travel chain stop was required for
personnel protection, and must be strictly controlled administratively. However, the
inspector determined that there was no documentation as to whether the actual setting
accounted for the special fixture's height. The inspector questioned the fuel handler who
had checked the chain stops and determined that the stops did not actually require
adjustment to account for the thicker lower rotating inspection fixture, although this was
not clearty documented. The inspector reviewed Work Request 000Z978296 and
determined that the work step could not be followed as written. The work step stated:
" Adjust the chain stop on the fuel prep machines to allow at least 6 ft of water
- above top of fuel per 23.710."
The inspector noted that Section 4.1 of " Procedure 23.710", set the chain stop using an
indirect measurement to obtain 6 feet of water depth. With the thicker inspection fixture
installed, following the procedure would have resulted in only 5.5 feet of water above the
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top of the fuel. The work request did not state that an abnormal fixture height needed to
be accounted for in the setting of the chain stop. The inspector attempted to verify the
basis for the specified setpoint for the upper chain stops. The system engineer stated
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that the setpoint for the chain stop was measured by placing a dummy bundle in the FPM
at a depth of 6 feet, then measuring the corresponding distance between the footplate
and a point on the carriage. This indirect measurement allowed setting the chain stop
without a bundle in the FPM, and was implemented as a procedure section in 23.710.
The inspector determined that this method of calculating a setting for a design feature of
the FPM was informal, lacked adequate verifications, and was never documented. The
setting represented a non-conservative change from the original vendor-specified setpoint
of 6 feet 3-3/4 inches to 6 feet 0 inches and was never evaluated. It was conservative
relative to a similar TS limit for the refueling bridge grapple. Also, a plant modification
package for installing a radiation monitor interlock to stop the FPM travel did not
document the setpoint or basis, and no functional check of the interlock had been
performed since original Mstallation.
The inspector determined that the FPM was not identified as a quality piece of equipment,
and it did not perform any safety function. Thus, the formal design control measures of
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10 CFR Part 50, Appendix B did not apply to the FPM. However, the personnel protection
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function for the FPM was clearly important. It was directly analogous to the upper travel
limit for the refueling bridge grapple, which was controlled by TS.
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The licensee acknowledged the importance of this design function. In response to these
concerns, engineering personnel began a design and licensing basis review of all fuel
handling system equipment. Specific documentation deficiencies were scheduled to be
corrected.
c.
Conclusions
The inspector identified a lack of formal design control measures and documentation for
the fuel preparation machine's upper travel limit and radiation monitor interlock. No
regulatory requirements were violated.
Engineering Staff Training and Qualification
E5.1
Refuelina Floor Worker Qualifications
a.
Inspection Scope (86700)
The inspector reviewed training and qualification records for individuals performing work
during the fuel inspections, both for the licensee and the vendor.
b.
Observations and Findinas
The inspector identified that licensee personnel involved in fuel handling activities
received little formal training. This included the refueling floor coordinators. Familiarity
with the work was gained primarily through on the iob training. The only formal
qualification associated with fuel handling was for refueling bridge operators. Personnel
who were considered to have the necessary skills and experience by licensee
management were not formally designated as such.
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The inspector determined that the licensee placed a heavy reliance on the experience
and expertise of the vendor's personnel. The licensee did not take any action to
determine the amount and content of training provided by the vendor to the workers hired
at Fermi. While quality assurance inspector certifications were verified properly,
familiarity with the work procedures was not checked. This was important because the
licensee designated the vendor's procedures as reference use procedures, so the
procedures were not required to be in-hand and followed step by step.
The inspectors questioned licensee personnel supervising the fuel inspections about
response to fuel handling mishaps. Responses indicated a lack of detailed knowledge
and training for such situations. The inspector reviewed all applicable station procedures
for responding to a fuel handling mishap and concluded that the procedures only
addressed a high radiation or airborne radioactivity condition. A lesser mishap was more
likely based on industry experience. The inspector identified that the licensee did not
have a specific procedure for combating irradiated fuel damage while refueling. However,
interviews with senior reactor operators indicated that sufficient guidance to respond was
available. Licensee management stated that procedural guidance would be improved in
response to this concern. Procedures from other nuclear stations were under review at
the conclusion of this inspection.
c.
Conclusions
The inspector concluded that the licensee had an informal training and qualification
process with respect to refueling area work tasks. No specific deficiencies related to
training were identified and workers were observed to be knowledgeable of the work
activities. However, knowledge weaknesses were noted in emergency response to a fuel
handling mishap.
111. Plant Support
R.
Radiological Protection and Chemistry Controls
R1.1
Excellent Radiation Protection Support of frradiated FuelInspection
a.
Inspection Scope (71750)
The inspector observed radiation protection support and radiation worker practices for
irradiated fuelinspection activities. Briefing notes and work instructions were reviewed.
b.
Observations and Findinas
Radiation protection personnel were closely involved in all phases of the preparation and
execution of the fuelinspections. A radiation protection technician experienced in
refueling area activities was assigned continuously to support the work. The inspector
observed excellent support of the work. Radiation and contamination surveys were
promptly taken as conditions changed.
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Workers were observed to exercise good radiation worker practices. Communications of
expected changes in radiological conditions were made prior to any changes.
Contamination control was good, and no personnel contamination events occurred during
the work.
The inspectors observed good foreign material controls and tool accountability during the
work. A member of the licensee's Independent Safety Engineering Group was observed
conducting a surveillance of these practices and promptly initiated corrective actions for
minor deficiencies identified during the surveillance.
c.
Conclusions
The inspectors observed that radiation protection personnel were closely involved in all
phases.of the preparation and execution of the fuelinspections. Workers were observed
to follow good radiation worker practices. The inspectors observed good foreign material
controls and tool accountability during the work.
IV. Manaaement Meetinas
X.
Exit Meeting Summary
The inspector presented the inspection results to members of licensee management at the
conclusion of the inspection on February 26,1998. The licensee acknowledged the findings
presented. The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
- Licensee
D. Cobb, Operations Superintendent
P. Fossier, Plant Manager
E. Heitzenrater, NSS, Operations
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T. Hsieh, Nuclear Fuels Supervisor
.W. O'Connor, Manager of Nuclear Assessment
N. Peterson, Acting Director, Nuclear Licensing
J. Plons, Technical Director
T. Schehr, Operating Engineer
S. Stasek, Supervisor, independent Safety Engineering Group
- J. Thorson, Nuclear Engineering Supervisor
W. Tucker, Supervisor Nuclear Fuels and Reactor Engineering Group
NRC
A. Kugler, Fermi 2 Project Manager, NRR
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15'
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INSPECTION PROCEDURES USED
IP 37551:
Onsite Engineering
IP 37700:
Design Changes and Modifications
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
IP 62707:
Maintenance Observation
IP 71707:
Plant Operations
IP 71750:
Plant Support Activities
IP 86700:
Spent Fuel Pool Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-341/98004-01
DEV
frradiated Fuel Stored Overnight in the FPM
50-341/98004-02
Inappropriate Instruction for Fuel Handling
50-341/98004-03
Lack of Critical Controls During Fuel Bundle Disassembly
Closed
None.
Discussed
None.
,
16
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LIST OF ACRONYMS USED
DEV
Deviation -
Fuel Preparation Machine
NRC.
Nuclear Regulatory Commission
Nuclear Shift Supervisor -
Refueling Floor Coordinator
TS
Technical Specification
Updated Final Safety Analysis Report
Violation
17