ML20237A294
| ML20237A294 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/07/1987 |
| From: | Gardner R, Gautam A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237A236 | List: |
| References | |
| 50-341-87-39, IEB-79-01, IEB-79-1, NUDOCS 8712140386 | |
| Download: ML20237A294 (11) | |
See also: IR 05000341/1987039
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/87039(DRS)
Docket No. 50-341
License No. NPF-43
Licensee:
Detroit Edison Company
2000 Second Avenue
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Detroit, MI 48224
Facility Name:
Fermi 2
Inspection At:
Fermi 2 site and Glen Ellyn, Illinois
Inspection Conducted:
September 21 through November 9, 1987
Inspector:
A. S. Gautam
.C
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Date
Also participating in the inspection and contributing to the report were:
M. Kopp, RIII
J. Jacobson, NRR
J. McGhee, INEL
H. Stromberg, INEL
M. Trojovsky, INEL
L. Bustard, Sandia
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Approved By:
R. N. Gardner, Section Chief
flant Systems Section, Region III
Date
Inspection Summary
Inspection on September 21 through November 9, 1987 (Report No. 50-341/87039(DRS))
Areas Inspected:
Special announced safety inspection of the environmental
qualification (EQ) of electric equipment within the scope of 10 CFR 50.49.
The inspection included licensee action on SER/TER commitments; EQ program
compliance to 10 CFR 50.49; adequacy of EQ documentation; and a plant physical
inspection of EQ equipment (Modules No. 30703 and 25576).
Results:
The licensee has implemented a program to meet the requirements of
Deficiencies identified in the areas inspected are summarized
below:
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VIOLATIONS
Item No.
O_escription
Report Section
50-341/87039-006(DRS)
Weidmuller terminal blocks found
3.a
unqualified based on inadequate
documentation.
50-341/87039-007(DRS)
AVC0 solenoid valves found
3.b
unqualified based on inadequate
documentation.
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POTENTIALLY ENFORCEABLE / UNRESOLVED ITEM
Item No.
Description
Report Section
50-341/87039-003(DRS)
Deficient Raychem splices used
2.c(3)
in 10 CFR 50.49 circuits.
50-341/87039-004(DRS)
Failure to demonstrate qualification
2.c(4)
of nylon wire nuts in Limitorque
operators.
OPEN ITEMS
Item No.
Description
Report Section
50-341/87039-001(DRS)
Incorporation and implementation of
2.c(1)
EQ maintenance and surveillance
requirements into the EQ program.
50-341/87039-002(DRS)
Recalculation of qualified life for
2.c(2)
any affected equipment in the drywell
for temperatures identified to be
in excess of aging temperature used
in EQ documentation.
50-341/87039-005(DRS)
Lack of formal EQ training for
2.e
maintenance personnel.
50-341/87039-008(DRS)
Lack of specific instrument loop
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accuracy calculations.
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DETAILS
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1.
Person Contacted
a.
Detroit Edison Company
- R. Sylvia, Group Vice President
- F. Agosti, Vice President, Nuclear Engineering
- R. Lenart, General Director, Nuclear Engineering
- J. Lemon, Director, Plant Safety
- T. Randazzo, Director, Regulatory Affairs
- G. Trahey, Director, Nuclear QA
L. Schuerman, General Supervisor, Nuclear Engineering
+*Q. Dong, Supervisor, Nuclear Engineering
- L. Wooden, Supervisor, Nuclear Technology
- J. Rotundo, Supervisor, Maintenance Support
L. Fron, Supervisor, Mechanical / Fluid Systems
- L. Bregni, Senior Engineer, Licensing
- L. Grant, Lead EQA
- F. Konja, EQ Engineer
- K. Bandyopadhyay, EQ Engineer
- J. Kilpatrick, EQ Engineer
- L. Raizanen, EQ Engineer
- M. Bowery, EQ Engineer
- M. Baxi, EQ Engineer
- E. Opland, EQ Coordinator, Maintenance
- K. Faulk, EQ Coordinator, Maintenance
b.
Consultants-
P. DiBenedetto, DiBenedetto Associates
- M. Spisak, Sargent & Lundy
- S. Akhtar, Sargent & Lundy
- A. Behera, Sargent & Lundy
c.
Nuclear Regulatory Commission (NRC)
- W. Rogers, Senior Resident Inspector
- U.
Potapovs, NRR
- Denotes those attending the interim site exit meeting on September 25,
1987.
+ Denotes those attending the exit interview on November 9, 1987, at the
conclusion of the inspection.
2.
EQ Program Compliance to 10 CFR 50.49
The inspectors reviewed selected areas of the licensee's EQ program to
verify compliance to 10 CFR 50.49.
The licensee's EQ program was found
to identify methods of equipment qualification; provide for evaluation
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and maintenance of EQ documentation in an auditable form; provide for
upgrading of replacement equipment; and provide for control of plant
modifications. Based on their review, the inspectors determined that the
licensee had established an adequate EQ program in compliance with the
requirements of 10 CFR 50.49. The licensee's methods for establishing
and maintaining the environmental qualification of electrical equipment
were reviewed in the following areas:
a.
EQ Program Procedures
The inspectors examined the adequacy of the licensee's policies
and procedures for establishing and maintaining the environmental
qualification of equipment within the scope of 10 CFR 50.49.
The
licensee's EQ program was reviewed for procurement of qualified
equipment; maintenance of qualified equipment; modifications to the
plant that could affect qualified equipment; updating of the EQ
master list; and review and approval of EQ documentation.
Procedures reviewed included the following documents:
NE Procedure 6.02, EQ Central Files, Revision 0
NE Procedure 6.7, EQ Review of Design Change Documents,
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Revision 0
P0M 12.000.113(SQ), Nuclear Production EQ Program,
Revision 0
N0P 120, Environmental Qualification, Revision 0
NE Procedure 6.5, EQ Review Design Calculations, Revision 0
POM 12.000.017(SQ), Preventive Maintenance Program,
Revision 6
NE Procedure 6.6, EQ Maintenance and Surveillance Program,
Revision 2
NE Procedure 6.03, EQ Equipment Upgrade / List Methodology,
Revision 0
NE Procedure 6.8(SQ), Identification and Disposition
of Potential Noncompliance to 10 CFR 50.49, Revision 0
NE Procedure 6.1, EQ Manuals and Updates, Revision 0
P0M 12.000.015(SQ), Work Requests, Revision 28
NQAP Procedure 1801, Audits, Revision 8
Specific areas reviewed in these procedures included definitions
of harsh and mild environments, equipment qualified life, service
conditions, periodic testing, maintenance and surveillance, and
upgrading of replacement equipment purchased after February 22, 1983.
No violations of NRC requirements were identified,
b.
10 CFR 50.49 Master Equipment List (MEL) of EQ Equipment
IE Bulletin No.79-01B required licensees of all power reactor
facilities with an operating license to provide a MEL that
identified each Class IE electrical equipment item relied upon
to perform a safety function during a design basis event.
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10 CFR 50.49, Paragraph (d), requires licensees to prepare a
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list of electrical equipment important to safety and within the
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scope of the rule.
The NRC inspectors reviewed the licensee's
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MEL for compliance to 10 CFR 50.49.
Areas reviewed included
adequacy of the MEL, technical justifications for removal of
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items from the MEL, and licensee reviews of the MEL for changes
due to field modifications.
The inspectors verified the
completeness / adequacy of the list in terms of equipment needed
during accident conditions through review of piping and
instrumentation drawings (P& ids), emergency procedures, technical
specifications, and FSARs.
Since Fermi 2 E0Ps do not reference specific plant instruments
when describing required operator actions, the inspectors selected
safety-related equipment that the operators would be expected to use
during an accident.
Plant emergency procedures reviewed in regard to
the MEL included Reactor Level / Pressure Control (Proc. 29.000.01),
Primary Containment Control (Proc. 29.000.03) and Reactivity Control
(Proc. 29.000.08).
P& ids were reviewed for the Core Spray (CS)
System, Residual Heat Removal (RHR) System, Reactor Core Isolation
Cooling (RCIC) System, High Pressure Coolant Injection (HPCI) System,
Combustible Gas Control (CGC) System, Reactor Water Cleanup (RWCU)
System, and Standby Liquid Control (SLC) System.
Selected equipment
was verified to be part of the Fermi 2 MEL.
No violations of NRC Requirements were identified.
c.
EQ Maintenance and Surveillance Program
The inspector reviewed specific maintenance, component parts
replacement, surveillance tests, and inspections necessary to
preserve the environmental qualification of EQ equipment identified
on the MEL.
EQ requirements in the licensee's maintenance
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procedures and EQ binders were reviewed against maintenance records
of selected equipment to verify performance of maintenance and
surveillance activities at prescribed intervals, including gasket
inspection, lubrication, torquing of housing covers and installation
of replacement parts.
The following exceptions were identified:
(1) The inspector observed that certain EQ requirements had
not yet been incorporated into the licensee's maintenance
and surveillance programs, and that several EQ maintenance
requirements had not yet been implemented in the field.
The licensee stated that the Fermi 2 SER, Supplement No. 5,
Section 3.11.5 allowed Fermi 2 to not fully implement their
EQ maintenance program until the plant reached full power
operation.
In response to the inspector concerns, however,
the licensee agreed to do the following:
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Incorporate all EQ n Mtenance and surveillance
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rm Mrements into tt
r EQ program prior to startup
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Licir current occage.
Review past maintenance and surveillance records to
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verify if any EQ equipment had been compromised due to
missed activities.
If such deficiencies were found,
the licensee agreed to rework the equipment or justify
its operability prior to startup.
Implement all EQ maintenance and surveillance
requirements prior to full power operation.
Subsequent to these findings the inspectors confirmed through
a very limited review that the licensee had taken corrective
action by incorporating appropriate EQ maintenance and
surveillance requirements into their EQ program.
The licensee
also r2 worked or justified the operability of equipment in
cases where maintenance may have been missed.
Region 111 shall
perform a detailed inspection to further review the licenstie's
corrective action.
Pending further NRC review of this corrective action, this is
considered an Open Item.
(50-341/87039-001(DRS))
(2) Monitoring Drywell Area Temperatures
The NRC has recently identified a generic industry concern
regarding BWR containment temperatures being possibly higher
than temperatures considered in the aging calculations of
10 CFR 50.49 designated equipment.
The licensee stated that
in order to address this NRC concern the Fermi 2 Nuclear
Station has in place a program for monitoring drywell area
temperatures during power ascension.
Input from this program
shall be used to verify / validate analytical values used in
determining the qualified life of Fermi 2 EQ equipment.
This
program uses temporary and permanent thermocouple to obtain
area temperatures at various power levels and environmental
conditions, and is scheduled to continue for one year after
the commercial (full power) operation date.
In particular,
containment temperatures will be monitored during the hottest
day in summer at full power.
Data accumulated to date
indicates that some areas of the drywell above 611' elevation
will see normal conditions in excess of the 135 F containment
average ambient temperature.
Fermi 2 has utilized this
information to recalculate the qualified life for affected
equipment.
Pending further NRC review this is considered an Open Item.
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(50-341/87039-002(DRS))
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(3) Raychem Splices
The licensee identified numerous deficiencies in the
installation of Raychem splices used in 10 CFR 50.49 circuits.
Most deficiencies appear to be qualifiable through new testing;
however, some deficiencies have not yet been demonstrated to be
qualifiable.
Pending further review by the licensee and the NRC this is
considered a Potentially Enforceable / Unresolved Item.
(50-341/87039-003(DRS)
d.
Plant Procurement and Upgrading of Replacement Equipment
Licensee procejures were found to adequately address upgrading
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of replacement equipment purchased after February 22, 1983.
Procurement procedures and documents were found to adequately
address appropriate quality and regulatory requirements regarding
the environmental qualification of equipment within the scope of
Checklists were observed to have been used to provide
evidence of reviews and approvals.
Procurement packages for the
replacement of equipment were found to properly address upgrading
of replacement equipment to the requirements of IEEE 323-1974.
No violations of NRC requirements were identified.
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e.
Quality Assurance (QA) and Training Program
During this review the inspectors determined that the licensee had
implemented a program to monitor the quality of EQ activities
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through surveillance, audits, and reviews of the records and files
for plant modifications and equipment procurement.
NRC inspectors
reviewed the licensee's QA audits including QA Audit
No. A-05-P/TS-86-17 conducted in May 1986.
The inspectors found
the methodology, results and followup corrective action relative
to the audit acceptable.
No violations of NRC requirements were
identified.
The NRC inspectors also reviewed the licensee's staff training
program and associated records relative to the performance of EQ
activities.
The training records indicated that the licensee had
implemented a training program for key engineering personnel,
including management; however, maintenance personnel responsible
for EQ activities were observed to have not been formally trained.
Current training for maintenance personnel consists of informal
instruction. reading of procedures and news letters.
The licensee
agreed to upgrade their training program for maintenance personnel.
Pending further NRC review this is considered an Open Item.
(50-341/87039-005(DRS)
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3.
Detailed Review of Qualification Files
The licensee qualified their EQ equipment to the requirements of NUREG-05b3
CAT II (10 CFR 50.49, Paragraph K).
The inspectors reviewed over
30 equipment qualification files for evidence of the environmental
qualification of equipment within the scope of 10 CFR 50.49.
Files were
found to include a full description of the equipment; similarity analysis
of tested equipment to that installed in the plant; allowed mounting
methods and orientation; qualification of interfaces (conduit housing,
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seal, etc.); evaluation of aging effects on equipment; description of
test sequence and methodology; environmental conditions for the equipment
during an accident; qualification for submergence of applicable equipment;
resolution of test anomalies; and maintenance / surveillance criteria for
the preservation of the qualified status of equipment.
The inspectors selectively reviewed the above areas, as applicable,
including special reviews for the required duration of operability of
equipment; licensee evaluation of tested materials and configurations
relative to actual plant installations; adequacy of test conditions;
aging calculations for qualified life and replacement intervals; effects
of decreases in insulation resistance on equipment performance; adequacy
of demonstrated accuracy of equipment and interfaces during an accident;
and licensee evaluations of discrepancies identified in IE Notices and
Bulletins.
EQ files were reviewed for electrical cables, cable splices,
terminations, terminal blocks, electrical motors, solenoid valves,
electrical penetrations, seals, lubricants, transmitters, temperature
elements, radiation monitors, control and position switches, switch
gear, control panels and miscellaneous electrical devices.
The inspectors identified various deficiencies in the EQ documentation
contained in the licensee's EQ files.
Details are noted below:
a.
Weidmuller SAK Terminal Blocks (EQ1-EF2-101)
This file was used to demonstrate the qualification of Weidmuller
SAK terminal blocks for use inside the drywell in 120 VAC control,
460 VAC power, and thermocouple instrumentation circuits.
The
inspector noted that the test data did not conclusively demonstrate
operability of the terminal blocks at 460 VAC.
The qualification file described a generic test during which the
Weidmuller SAK terminal blocks were enclosed in NEMA 4 enclosures
and exposed to LOCA/ Spray conditions.
Whenever cold sprays were
initiated, the one amp circuit breakers would fail.
Failure of
the one amp circuit breakers did not occur when the 600 VAC applied
voltage was reduced to approximately 150 VAC.
Therefore,
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operability at 460 VAC was not demonstrated.
Subsequent to this
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finding, the licensee provided additional documentation to
demonstrate that the terminal blocks were qualifiable.
The licensee
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was informed that the above finding was considered a violation of
10 CFR 50.49, Paragraph (f), failure to qualify equipment by test
or analysis prior to the EQ deadline of November 30, 1985.
This is considered a Level IV violation (Supplement ID).
(50-341/87039-006(DRS))
b.
AVC0 Solenoid Valve Assemblies (EQ1-EF2-220)
This file was used to demonstrate qualification of AVC0 solenoid
valve assemblies for use inside the drywell and steam tunnel on the
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MSIVs. The equipment qualification to NUREG-0588, Category II, was
based on a Wyle Laboratory test report 17514-1, Revision A, " Nuclear
Environmental Qualification Test Program on a MSIV Pneumatic Control
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Manifold," dated July 18, 1985, and Addendum I to Wyle Test
Report 17514-1, dated March 21, 1985.
During the test aging sequence, the component was aged to simulate
forty years of qualified life.
Following the aging, the assembly
was functionally tested.
The assembly failed the functional test by
sticking in an intermediate position.
The valve was disassembled
and the failure researched.
The failure was determined to have been
caused by the hardening of the lubricant (Parker Super-0-lube) due to
excessive lubrication and high radiation.
The lubricant was removed
and the assembly lubricated with a substitute (Houghton 620). A
functional test was satisfactorily performed after reassembly. LOCA
testing was then performed.
The assembly was functionally tested
and again stuck in the intermediate position. Like the first time,
this failure was determined to be the result of lubrication failure
at high radiation.
The inspectors were concerned that based on
inadequate test documentation, operability under accident conditions
had not been addressed.
The licensee provided additional documentation in their files to
support the Parker Super-0-lube qualification for radiation; however,
the inspectors concluded that the file did not demonstrate the
qualification of the AVC0 when operated in conjunction with the
lubricant under radiation conditions.
Subsequent to this finding,
the licensee provided additional documentation to demonstrate that
these valves were qualifiable.
The licensee was informed that the
above finding was a violation of 10 CFR 50.49 paragraph (f), failure
to qualify equipment by test or analysis prior to the EQ deadline of
November 30, 1985.
This is considered a Severity Level IV violation (Supplement ID).
(50-341/87039-007(DRS))
c.
Instrument Accuracy
During review of instruments required to perform a safety function
during an accident, the inspectors observed that the licensee did
not have site specific instrument loop accuracy calculations to
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justify the performance of the instruments and their interfaces
(cables, terminal blocks, connectors) during harsh accident
conditions.
Fermi 2 SSER 5, Section 3.11.5.1, states that the
technical specifications for instrument channel setpoint allowable
values issued for GE/BWR plants (based on the GE setpoint methodology
developed to date) were sufficiently conservative to permit licensing
of the Fermi plant.
The SER, however, required the licensee to
perform a confirmatory review of plant specific loop accuracy to
verify that all EQ instruments would perform satisfactorily under
harsh conditions.
In a separate letter (Memo from 8. Youngblood,
NRC, to J. Grolyn, Chairman, Utility Licensing Review Group,
February 19, 1985) NRR also apparently indicated to the licensee
that this confirmatory review may start after NRR had reached a
conclusion on the conservatism of the GE setpoint methodology.
This letter further stated that subsequent to a NRR conclusion on the
GE setpoint methodology, the licensee would have six months to
confirm if their instrument accuracy was adequate for plant specific
applications.
The regional team was concerned that such a schedule may result in
the licensee operating with unqualified instruments.
Consequently,
the inspectors reviewed six instrument loops and concluded that the
loop accuracy was consistent with the plant tech specs.
Based on
NRR's SER comments as well as a Region III discussion with NRR on
this subject, the inspectors identified no immediate safety concerns
regarding the operability of the plant.
The licensee stated that
they had completed their confirmatory review for about 30% of the
plant instrument loops but did not expect to complete this review by
full power operation.
The licensee was informed by the inspectors
that even though this issue would be further reviewed with NRR,
Region III will expect the licensee to have completed their
confirmatory review for the accuracy of all affected instrument
loops prior to full power operation.
Pending further review of licensee calculations, this is considered
an Open Item.
(50-341/87039-008(DRS))
d.
Nylon Wire Caps in Limitorque Operators
The licensee identified the installation of nylon wire caps in over
fifty-eight EQ Limitorque operators.
Qualification of nylon wire
caps has not been demonstrated by the Limitorque test report.
The
licensee has reworked five of these actuators to install Raychem
splices, and determined that the remaining operators would either
not see condensing steam or would not be affected by steam conditions.
This evaluation has not yet been accepted by the inspectors.
The
nylon caps are scheduled to be LOCA tested by another licensee at
the Wyle Labs by February 1988.
Interim testing submitted by this
licensee was considered adequate for the interim operation of Fermi.
Pending further review this is a Potentially Enforceable / Unresolved
Item.
(50-341/87039-004(DRS))
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4.
Plant Physical Inspection
The NRC inspectors selected over 40 items on the MEL for examination in
the plant.
The EQ file of each item had been reviewed, and information
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regarding the location, manufacturer, model/ serial number, mounting,
orientation, environment, and interfaces had been noted.
The inspectors
examined the selected items in the field, as accessible, and verified
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that the method of installation of each item was not in conflict with
its environmental qualification.
Specific areas reviewed included
traceability of the installed items to the EQ files, ambient environmental
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conditions, qualification of interfaces (connectors, wires, seals,
insulation, lubricants, etc.), evidence of significant temperature rise
from the process fluid, drainage, mounting methods, physical conditions
and housekeeping.
No violations of NRC requirements were identified.
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5.
Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involve some action
on the part of the NRC or licensee or both.
Open items disclosed during
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this inspection are discussed in Paragraphs 2.c(1), 2.c(2), 2.e, and 3.c.
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6.
Potentially Enforceable / Unresolved Items
An unresolved item is a matter about which more information is required
in order to ascertain whether it is an acceptable item, an open item, a
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deviation, or a violation.
Potentially Enforceable / Unresolved Items are
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unresolved items, which if ascertained to be a violation may be followed
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up with enforcement action in accordance with NRC enforcement guidance on
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environmental qualification.
Potentially Enforceable / Unresolved Items
are discussed in Paragraphs 2.c(3) and 2.c(4).
7.
Exit Interview
The Region III inspectors met with the licensee's representatives
(denoted under Paragraph 1) during an interim exit on September 25, 1987,
and discussed their findings by phone at the conclusion of the inspection
on November 9, 1987. The inspectors summarized the purpose and findings
of the inspection and the licensee acknowledged this information.
The
licensee did not identify any documents / processes reviewed during the
inspection as proprietary.
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