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{{Adams | |||
| number = ML20148N147 | |||
| issue date = 06/19/1997 | |||
| title = Insp Rept 50-341/97-05 on 970512-30.Violations Noted. Major Areas Inspected:Maint & Engineering | |||
| author name = | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000341 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-341-97-05, 50-341-97-5, NUDOCS 9706260127 | |||
| package number = ML20148N136 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 22 | |||
}} | |||
See also: [[see also::IR 05000341/1997005]] | |||
=Text= | |||
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; U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION lll | |||
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Docket No: 50-341 ! | |||
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License No: NPF-43 1 | |||
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Report No: 50-341/97005(DRS) | |||
Licensee: Detroit Edison Company | |||
Facility: Enrico Fermi, Unit 2 | |||
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l Location: 6400 N. Dixie Highway | |||
j Newport, MI 48166 | |||
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Dates: May 12 through May 30,1997 | |||
Inspectors: M. Miller, Reactor Engineer | |||
D. Chyu, Reactor Engineer | |||
H. Walker, Reactor Engineer | |||
Approved by: Mark Ring, Chief, Lead Engineers Branch | |||
j , Division of Reactor Safety | |||
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9706260127 970619 ' | |||
PDR ADOCK 05000341 | |||
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EXECUTIVE SUMMARY | |||
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Enrico Fermi, Unit 2 | |||
NRC Inspection Report 50-341/97005(DRS) | |||
1 | |||
l This inspection included aspects of licensee maintenance and engineering. The purpose | |||
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of the inspection was to assess the conduct and control of your surveillance and | |||
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maintenances activities. The enclosed report presents the results of that inspection. | |||
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Maintenance | |||
* | |||
The emergency diesel generator 12 outage showed the licensee's ability to plan and | |||
execute a maintenance activity in a controlled and efficient manner (Section M1.1). | |||
* | |||
The corrective actions to control measurement and test equipment (M&TE) have | |||
had positive results in resolving past problems with delinquent return of equipment | |||
and with delayed evaluation of the effects on equipment tested with M&TE that | |||
failed as-found calibrations (Section M1.2). | |||
* | |||
One violation with two examples was identified concerning poor control of | |||
surveillance and post-maintenance testing on the diesel fire pump (Section M1.3). I | |||
* | |||
The use of the licensee's minor maintenance program called, " Tool Pouch | |||
Maintenance," on fused disconnect switches resulted in the lack of documentation | |||
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for repetitive failures of the switches (Section M1.4). | |||
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* | |||
The inspectors identified three exemples and one violation of workin0 outside the | |||
work scope or a lack of documentation of work performed in the field. In addition, | |||
muitiple barriers such as the electrical maintenance personnel, their supervisors, and | |||
a quality control (OC) inspector failed to identify this violation (Section M3.2). | |||
* | |||
One weakr ess was identified for a lack of procedural control for cannibalizing parts | |||
* | |||
from spare motor control center (MCC) positions when spare parts were not | |||
available from the warehouse (Section M6). | |||
Enaineerina | |||
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The engineering recommendation to not declare the diesel fire pump inoperable | |||
based on calculations which indicated the pump could fail the flow requirements at j | |||
low speed was non-conservative and lacked proper focus on equipment operability ] | |||
(Section M1.3). | |||
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Engineering personnel dM not demonstrate a clear understanding of proper ' | |||
lubrication levels for plant specific equipment. One unresolved item was identified | |||
concerning the determination of proper oillevel for rotating equipment ; | |||
(Section E2.1). j | |||
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* | |||
The inspectors noted several weaknesses in engineering support for maintaining the | |||
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plant. These weaknesses were: not knowing the expected break-in period for the ! | |||
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EDG alternator bearings and not trending the oil analysis with respect to the service | |||
time of the bearing and its oil (Section E2.2). | |||
* | |||
One violation was identified concerning inadequate design control for nonsafety- | |||
related parts used in safety-related systems. The licensee's response to material | |||
control issues appeared to be slow (Section E2.3). | |||
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Report Details | |||
1. Operations | |||
08 Miscellaneous Operations issues | |||
08.1 (Closed) Violation 50-341/95012-04b: Operations Conduct Manual MOPOS, | |||
"Cuntrol of Equipment,". was inadequate and was a contributor to a station battery | |||
problem. A battery charger was placed in service before maintenance and testing | |||
of the batteries had been completed. The inspectors reviewed Revision 5 of the | |||
manual and considered the changes to address this issue to be adequate. This item | |||
is closed, | |||
11. Maintenance | |||
M1 Conduct of Maintenance | |||
M 1.1 Emeraency Diesel Generator (EDG) 12 System Outaae | |||
a. Inspection Scope (62702 | |||
The inspectors observed ail or portions of the following work activities associated | |||
with the EDG outage and reviewed some completed work packages: | |||
* 000Z954038 Oilleaking from coupling and instrument | |||
* 000Z955261 Replace air receiver drain valve | |||
* | |||
000Z961121 Repair headshaft sleeve that has moved upwards | |||
* 000Z961758 Investigate noise coming from muffler internals | |||
e 000Z962346 EDG-12 fan is out of balance | |||
* 000Z967890 Flush inboard and outboard bearings | |||
* 000Z971260 Fuse 1 and 2 were noted to have loose clip i . Dase | |||
assembly | |||
* | |||
* 000Z973910 Replace gasket and washers on blower | |||
* R295940706 Electrically test time delay relay | |||
* R398940624 Inspect / test 480 volt motor control center (MCC) | |||
* R605960311 EDG 12 motor operated controlinspection | |||
* R609960311 Perform EDG 12 motor operated potentiometer | |||
inspection | |||
* S979940725 Recalibration of EDG 12 standby heater discharge | |||
control temperature switch | |||
* S999960327 Recalibrate 3 EDG 12 lube oil crankcase pressure "high" l | |||
i switches | |||
) * X895960315 X4103C003 - Inspect / test MCC, check fan, lobe motor | |||
l * X899960315 X4103C004 - Inspect / test MCC, check fan, lube motor | |||
b. Observations and Findinas | |||
The inspectors observed pre-job briefings in the electrical, mechanical, and | |||
instrumentation and control shops. Each supervisor used a checklist to ensure that | |||
management expectations for the pre-job briefing were addressed. Supervisors | |||
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I appeared knowledgeable of the jobs, provided useful informatica to the workers, | |||
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and were able to answer the worker's questions. Most workers appeared to have | |||
walked the jobs down before the briefings. | |||
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Supervision was present and actively involved with the workers at the job site. The | |||
major challenge to supervision was to ensure that the critical jobs were given | |||
priority when space conflicts existed. Overall coorciaation of the EDG 12 work | |||
activities was efficient and controlled. | |||
The inspectors observed the use of measurement and test equipment (M&TE) for | |||
the work activities. The equipment was properly checked out for the specific jobs, | |||
was within the specified calibration period, and was returned appropriately to the | |||
M&TE crib. Workers appeared knowledgeable about the proper use of the test | |||
equipment. This issue is further discussed in Section M1.2. | |||
The inspectors observed the use of the interim alteration checklist in documenting | |||
the lif ting and landing of electricalleads. The inspectors specifically noted that the | |||
checklists were filled out as the work progressed. Through direct observation, | |||
periodic checks, and review of completed work documents, the inspectors | |||
concluded that the interim alteration checklist was being used properly. | |||
Although the outage did not require any significant foreign material exclusion (FME) | |||
controls, the inspectors observed proper use of FME techniques for the jobs | |||
requiring some form of control. | |||
c. Conclusions | |||
The licensee expended significant effort in planning the activity and the results | |||
were good. Pre-job briefings were good and appeared to benefit from the use of a | |||
checklist. Supervision was present at the work site and provided useful input to | |||
personnel. Maintenance personnel showed clear capability to perform the tasks | |||
efficiently. | |||
' | |||
The EDG outage showed the licensee's ability to plan and execute a maintenance | |||
activity in a controlled and efficient manner. | |||
M1.2 Control of Measurement and Test Eauipment | |||
a. Insoection Scope (62703) | |||
The inspectors reviewed the use of M&TE because of previous problems identified | |||
in inspection Report 50-341/95008, Section 6.1.2. The scope included looking for | |||
equipment remaining in the field beyond the time allowed, M&TE being used on | |||
activities that the M&TE was not checked out for, and the ability to track where | |||
specific M&TE was used, when a calibration failed. | |||
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b. Observations and Findinas | |||
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The inspectors examined the signout documents for specific M&TE used for the | |||
EDG 12 outage, in each case, the M&TE was appropriately signed out for the | |||
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correct job and returned following the work. The inspectors examined records of | |||
other equipment and interviewed the attendant for the tool crib. The | |||
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documentation for M&TE appeared to track the use of the equipment appropriately. | |||
The licensee had recently implemented corrective actions for delinquent returns of | |||
M&TE. The new practice was to perform a weekly audit for delinquent equipment | |||
- and contact the supervisors of the persons responsible for the delinquent | |||
equipment. A one-day grace period was allowed for returning the M&TE. If the l | |||
equipment was not returned that day, the responsible person would lose his or her l | |||
privilege to check out any other M&TE until the delinquent equipment was returned. | |||
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The policy appeared to reduce the problem with delinquent equipment significantly. ! | |||
Another recent change addressed control of M&TE when an "as found" calibration | |||
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failed. Once M&TE failed a calibration, all plant equipment serviced by the suspect | |||
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M&TE needed to be evaluated to determine the effect of the calibration failure. The | |||
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licensee had been writing a single deviation event report (DER) for each failure and | |||
requiring each work group to address the particular work packages associated with | |||
the M&TE. The single DER provided little accountability and resulted in delajed | |||
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' evaluations. The licensee changed the method to writing a separate DER for each | |||
work group that used the failed M&TE. This resulted in an increased number of | |||
DERs associated with M&TE calibration failures but increased the accountability and | |||
, | |||
timeliness of addressing the effect on plant equipment. | |||
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c. Conclusions | |||
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The changes made to control M&TE have had positive results in resolving past I | |||
problems. No problems were identified during this inspection. Delinquent M&TE | |||
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was significantly reduced to an occasional single person having his or her privileges | |||
I suspended. The licensee recently had an 11-week period where no one had | |||
privileges suspended. | |||
M1.3 Inadeauate Testina of the Diesel Fire Pumo Followina Maintenance | |||
l a. Inspection Scope (62703) | |||
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During a review of Work Request 000Z975065, the inspectors noted that the diesel | |||
fire pump (DFP) speed had been lowered; however, the post-maintenance testing | |||
(PMT) did not address the resultant change in discharge pressure and water flow. | |||
The inspectors reviewed previous flow testing results and licensee actions to | |||
address the issue. | |||
b. Observations and Findinas I | |||
j' The inspectors reviewed the work request written to correct a deficiency with the | |||
l- diesel tripping on over speed. The work was signed off as satisfactory on May 11, | |||
! 1997. The inspectors noted that part of the corrective actions was to lower the ; | |||
l diesel speed from 2440 rpm to 2150 rpm. The inspectors questioned the effect on l | |||
; the fire pump flow and whether the current flow test would be invalidated. The l | |||
; inspectors also noted that the nuclear shift supervisor (NSS) had raised questions | |||
; concerning the effects of lowering the speed on the pump flow test. The NSS's | |||
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concern was documented in the work package and then lined out without any | |||
documented reason. The PMT was to perform a DFP weekly surveillance during , | |||
which only the discharge pressure was monitored. ' | |||
The licensee initiated a DER on May 27, in response to the inspector's questions, | |||
initial calculation by engineering suggested that the flow test could potentially fail | |||
! with lower engine speed. However, the DER stated, "This corrected data is | |||
theoretical and may vary from actual measured data. This data should not be used | |||
to classify the diesel fire pump as inoperable. Performing a flow test at the current | |||
engine speed will determine operability." The on-duty NSS reviewed the DER and | |||
declared the dieselike pump inoperable and entered th9 limiting condition for | |||
operation. | |||
On May 28, the licensee performed Fire Protection Procedure 28.504.003, " Fire | |||
Suppression Water System Simulated Auto Actuation Test," three times over a 12- | |||
hour period. The last attempt was successful. The acceptance criteria required a | |||
discharge pressure between 114.4 and 93.6 psig and the flow between 3375 and | |||
4125 gpm. The final test results had the discharge pressure at 94 psig and the l | |||
flow at 3407 gpm. Followi the satisfactory test, the licensee raised the diesel l | |||
speed to a band of 2250 to & , 7 rpm and succes*lly performed the surveillance | |||
again. | |||
Technical Specification (TS) 6.8.1 required that procedures covering the Fire l | |||
Protection Program shall be established, implemented, and maintained. The Detroit | |||
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Edison Maintenance Conduct Manual, MMA11, " Post-Maintenance Testing | |||
Guidelines," defined one criterion of satisfactory PMT as one that ensured no new | |||
or related deficiencies had been created by maintenance work. Following the | |||
maintenance work which changed a speed sensor switch, the diesel engine speed | |||
was also reduced. The PMT following the maintenance did not adequately address | |||
the effect of lowering the engine speed. Failure to properly test the DFP following i | |||
maintenance is an example of a violation of TS 6.8.1 (VIO 50-341/97005-01a). l | |||
, The inspector reviewed a previously completed DFP flow test 28.504.003 | |||
(completed May 2,1997) and noted the diesel speed was outside the acceptable | |||
limits based on the use of a strobe tachometer. The diesel speed was recorded as | |||
2440 rpm with the neceptable limits being 2100 to 2300 rpm. A note was entered | |||
on a discrepancy / resolution form stating that the installed tachometer was | |||
inoperative. No change was made to the procedure to allow the use of the strobe | |||
tachometer in piace of the installed engine tachometer and no justification was | |||
provided for accepting the out-of-limit engine speed. The section of the | |||
surveillance was signed off as satisfactory with the pump pressure at 114 psig and | |||
the flow at 3855 gpm. | |||
The test procedure noted that the fire pump pressure and flow were acceptance | |||
criteria but the procedure did not designate the diesel speed range as an acceptance | |||
criterion. However, the increased engine speed directly affected the pump | |||
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discharge pressure and flow acceptance criteria as demonstrated by the May 28 | |||
testing. The licensee failed to recognize the significance of the over speed | |||
condition and inappropriately accepted the test as valid. This is considered another | |||
example of a violation of TS 6.8.1 (VIO 50-341/97005-01b). | |||
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c. Conclusions | |||
The inspectors identified an example of poor control of a surveillance procedure and | |||
an example of inadequate post-maintenance testing. The licensee appeared to | |||
focus on. passing the tect rather than ensuring the equipment could perform its | |||
required function. The inspectors noted weaknesses in the licensee's review of | |||
completed packages and in the questioning attitude of multiple organizations. The | |||
entire problem with the fire pump could have been avoided by a critical review of | |||
the surveillance performed on May 2. , | |||
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Engineering's recommendation not to declare the DFP inoperable based on the | |||
calculation appeared non-conservative. The non-conservative decision making by | |||
engineering was further amplified by the extensive efforts necessary to pass the | |||
surveillance at the lower engine speed and the small margin with which it passed. | |||
Operations promptly recognized the problem with the DER and appropriately | |||
declared the DFP inoperable until the test proved otherwise. | |||
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M1.4 Tool Pouch Maintenance | |||
a. Inspection Scope (6703) j | |||
The inspectors reviewed the minor maintenance program called " tool pouch | |||
maintenance." This review included a review of the controlling procedure and | |||
discussions of the program with licensee personnel. | |||
b. Observations and Findinas | |||
During discussions with licensee personnel on problems with the fused disconnect | |||
switches in the ITE 480 volt MCCs, licensee personnel stated that maintenance | |||
assistance provided to operators in the closing of the MCC fused disconnect | |||
switches included cleaning and lubricating the fused disconnect switches. They | |||
further stated that these actions were appropriately covered under the " tool pouch | |||
, | |||
maintenance" program. | |||
l The inspectors reviewed Section 3.4.2 of MMA02, " Maintenance Program," | |||
I Revision 1, which described " tool pouch maintenance." Enclosure "B" of the | |||
procedure listed four pages of examples of work to be performed under the tool | |||
pouch maintenance program. This list, which was not all inclusive, did not list | |||
minor cleaning and lubrication. Since this type of work was not listed, there was | |||
some question about whether or not it should be included. The uses of tool pouch | |||
maintenance on fused disconnect switches resulted in the lack of documentation | |||
for repetitive failure of these switches. Therefore, the extent of the problem was | |||
l initially characterized incorrectly and was not considered significant. In addition, | |||
j the licensee erroneously considered that the inability to manually close the switches | |||
was not a failure of the switches, | |||
t c. Conclusions | |||
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: The use of " tool pouch maintenance" may be inappropriate for safety-related or | |||
{ important nonsafety-related equipment. Since records of this maintenance were | |||
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not normally prepared and retained, repetitive problems could be incurred without ! | |||
the knowledge of plant management, systems engineers or other personnel. The | |||
inspectors concluded " Tool pouch maintenance" would be inadequate for | |||
equipment or systems covered by the Maintenance Rule unless adequate controls | |||
were in place to ensure documentation and trending of repetitive equipment | |||
problems. | |||
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j M3 Maintenance Procedures and Documentation | |||
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M3.1 Lack of Documentation of Work Performed | |||
I a. Inspection Scope (62703) | |||
The inspectors reviewed work request (WR) package 000Z965287, " Torus Water | |||
; Management Recirculation Line Isolation Valve Rework," and identified one example | |||
; | |||
where the documentation of work performed in the work packages was unclear. | |||
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The inspectors also interviewed various licensee personnel and identified that | |||
i electrical maintenance personnel were assisting operations in closing electrical | |||
l disconnect switches without approval or documentation in work packagcc. | |||
4 b, Observation and Findinas | |||
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The inspectors identified an example of weak documentation of work gedormed in | |||
WR 000Z965287. The mechanics performed blue checks on the old and new valve | |||
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discs for valve G5100F609. The mechanics documented an unsatisfactory blue | |||
! check on the new disc, but a satisfactory blue check on the old disc. However, the | |||
! documents did not specify which valve disc was put back in the valve. The . | |||
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inspectors interviewed the supervisor who indicated that the old disc was put back | |||
in the valve because the blue check was satisfactory. | |||
In addition, licensee personnel indicated to the inspector that when operators could | |||
not manually close fused disconnect switches, electrical maintenance personnel | |||
, were requested to assist in the closure of the switches. The assistance involved | |||
lubricating the switches and sometimes pushing the switches closed with fuse | |||
pullers. However, the lubrication activities were neither authorized nor documented | |||
in any work packages. The inspectors did not identify any actual examples of this | |||
practice in the field. | |||
M3.2 Work Performed Outside the Packaae Scope | |||
a. Inspection Scoce (62703) | |||
The inspectors reviewed the followina packages: | |||
* 000Z965287- Torus water management recirculation line isolation | |||
valve rework | |||
* 000Z971595 Temperature switch electric: Control Room Heating, | |||
Ventilation and Air Conditioning (CCHVAC) chiller | |||
compressor unit oil temperature | |||
* 000Z958122 Fire protection diesel fire pump | |||
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* 000Z970741 Fire protection diesel fire pump | |||
* 000Z974256 MCC 72E-5A Position 3C | |||
* 000Z965876 Fire protection electrical driven fire pump outlet check | |||
valve | |||
* 000Z974392 MCC for torus water management system (TWMS) | |||
return to CS outboard isolation valve | |||
* 000Z961484 480 Volt motor control center No. 72C-2A | |||
* 000Z974393 Control rod drive pump room cooler | |||
* 000Z964774 CCHVAC emergency air north intake division 2 isolation | |||
damper | |||
b. Observations and Findinas | |||
Straiahtenina a Bent Valve Stem for a Nonsafetv-Related Valve Without Aporoved | |||
Work Packaae l | |||
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During the review of WR 000Z965287, the inspectors identified that a new valve l | |||
stem staged for valve G5100F609 rework was found bent and the mechanics | |||
straightened it without approved instructions in line packages. Mechanics were | |||
trained to check total indicated runuut (TIR) on new valve stems before installing | |||
them. The mcchartics identified that the TIR on the new stem was not within the | |||
specification of less than or equal to .0055 inches per foot. The mechanics then | |||
straightened the new stem, recorded the new TIR on the new stem, and put it in | |||
the valve. Although this action was documented in the package, straightening of | |||
the bent valve stem was not within the scope of the package. | |||
Work on a Safetv-Related Soare Switch Without Approved Work Packaae | |||
After restoring MCC 72E 5A Position 3C for TWMS return to residual heat removal | |||
outboard isolation valve, the MCC switch opened unexpectedly when an operator | |||
was closing the door. The switch was reclosed and remained closed. Due to this | |||
problem, on April 24,1997, electrical maintenance personnel performed | |||
* maintenance on the fused disconnect switch using Work Request OOOZ974256. | |||
After cleaning and lubricating the switch, the operation of the switch was | |||
unsatisfactory. The package was revised on April 25 to troubleshoot and replace | |||
necessary parts on the switch. On April 28, the electrical maintenance personnel | |||
swapped the folk, wing parts between MCC 72E-5A Positions BC (a spare fused | |||
disconnect switch) and 3C: the rotary switch, the lower fuse block, and the | |||
electrical disconnect switch. Following the swap, both switches failed after | |||
cleaning and lubricating. On April 29, electrical maintenance personnel recleaned, | |||
relubricated, and exercised the switch mechanisms. Both switches operated | |||
satisfactorily. | |||
The work package was initially revised to reflect using parts from the spare fused | |||
disconnect switch at Position SC; however, some activities were performed beyond | |||
the scope of the package as follows: | |||
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Placing the defective parts from MCC 72E-5A Position 3C back into the | |||
spare fused disconnect switch, | |||
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Cleaning and lubricating the spare fused disconnect switch which now | |||
contained defective parts from MCC 72E 5A Position 3C, and | |||
* | |||
Exercising the spare fused disconnect switch to ensure smooth operation of | |||
the switch. | |||
in addition, Step 7 of the work request package required that if spare parts were | |||
not available from the warehouse, personnel were to r$: move needed parts from the | |||
spare position of the MCC, document the action in the work request, and initiate a | |||
work request initiation form (WRIF) to work the spare position when parts were | |||
returned after refurbishment. However, on April 28, after the parts were removed | |||
from the spare position, maintenance personnel failed to initiate a WRIF for the | |||
spare position and performed work on the spare position without approved | |||
instructions. | |||
The inspectors were concerned this condition of working beyond the initial scope of | |||
the work request and failure to follow the work package were not recognized by the | |||
involved maintenance personnel, their supervisors, and the quality control (QC) | |||
inspector. Although the first QC inspector did not observe swapping of the parts | |||
between the switches, a second QC inspector during the package closecut review, | |||
did not recognize that the maintenance personnel had worked outside the scope of ; | |||
the package. The licensee did not recognize the inappropriateness of working on j | |||
the spare fused disconnect switch until prompted by the inspectors. | |||
l | |||
l | |||
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," | |||
required, in part, that activities affecting quality shall be prescribed by documented | |||
instructions, procedures, or drawings, of a type appropriate to the circumstances ! | |||
and shall be accomplished in accordance with these instructions, procedures, or | |||
drawings. Failure to have appropriate instructions or procedures for performing | |||
maintenance on the MCC 72E-SA Position SC is a violation of 10 CFR 50, l | |||
Appendix B, Criterion V (VIO 50-341/97005-02). | |||
M3.3 Conclusions on Maintenance Procedures and Documentation | |||
* | |||
The inspectors identified four examples where activities were performed outside the | |||
scopes of the work packages or where work documentation lacked detail. The four | |||
examples were: | |||
l | |||
* | |||
A lack of documentation in the use of a valve disc in the torus water | |||
management system, | |||
* | |||
A lack of documentation for lubrication and manual assistance of closing | |||
electrical disconnect switches, | |||
* | |||
Straightening a bent valve stem which was beyond the initial work | |||
instruction, and | |||
* | |||
Performing maintenance on a spare fused disconnect switch which was | |||
beyond the scope of the work package for repairs of another switch. | |||
A violation of 10 CFR 50, Appendix B, Criterion V, was identified for the last | |||
l example. The inspectors randomly sampled 15 work packages and identified | |||
; deficiencies with three work packages (Two packages were discussed in this | |||
section and the third package was discussed in Section M1.3). The inspectors | |||
11 | |||
l | |||
r ; | |||
. | |||
t | |||
were concerned that 20 percent of the sampled packages contained errors or | |||
violations not previously identified by multiple Detroit Edison personnel. | |||
The inspectors concluded that work documentation in selected packages was poor | |||
because the packages were not stand alone documents and did not contain | |||
sufficient detail for work performed in the field. | |||
M3.4 Procedural Detail and Skill of the Craft | |||
a. Insoection Scope (62703) | |||
The inspectors observed work activities and noted cases where the work results did | |||
not match what was expected. 1 | |||
b. Observations and Findino3 | |||
Following the EDG 12 outaga the inspectors noted that the oil levels for the | |||
alternator bearing were below the scribed line on the sight glass. The licensee | |||
indicated that the oil had been appropriately filled but had settled after a few hours. | |||
This was due to the high visccsity of the oil. The work request neither provided , | |||
guidance on the appropriate level to fill the oil nor did it warn the mechanics to | |||
return later and recheck the oil level. l | |||
During the DFP flow testing, the inspectors noted personnel using a strobe ! | |||
tachometer to determine the speed of the fire pump. The individual did not notice l | |||
that the readinq obtained was twice the speed that was expected. When the | |||
inspector ques, ioned the value, the individual confirmed the reading with another | |||
strobe tachometer and documented the value. Later the system engineer pointed | |||
out that the strobe was flashing twice for each revolution. The correct reading was | |||
obtained and the correction was entered into the test procedure. | |||
During work on EDG 13, an instrument technician increased the frequency too | |||
* | |||
quickly during testing of a tachometer and he obtained and recorded the wrong | |||
value. During a second attempt, the frequency was increased more slowly and the | |||
correct value was obtained. There was no guidance to instruct the technician to I | |||
increase the frequency slowly and the technician demonstrated a need for such | |||
guidance. | |||
c. Conclusion | |||
The licensee appeared to depend on the skill of the craft and minimized specific | |||
guidance in the procedures, in these three examples the procedures were weak | |||
and did not contain adequate guidance for the skilllevel of the assigned craft | |||
personnel. | |||
12 | |||
_ _ | |||
_ - - .. - _ . - - , _ - _ . | |||
_ . - | |||
. \ | |||
l | |||
l | |||
\ | |||
l | |||
l | |||
I | |||
r | |||
M6 Maintenance Organization and Administration ! | |||
l | |||
M6.1 Lack of Control for MCC Replacement Parts | |||
l | |||
a. Inspection Scope (6270_3_1 | |||
The inspectors and the licensee quality assurance (QA) organization identified a lack 1 | |||
i | |||
of control for MCC parts replacement. The inspectors reviewed WR 000Z974256; | |||
DER No. 970875, dated May 28,1997, for QA Audit No. 97-0118; and Nuclear | |||
Generation Memorandum NPSC 97-0031. I | |||
b. Observations and Findinas | |||
l | |||
On April 25,1997, in response to a recent problem with MCCs, the licensee issued | |||
a memorandum delineating an alternative method to obtain MCC replacement parts. | |||
It stated that, "if the required parts are not available from the warehouse and there | |||
is a spare MCC position which is also Q or Q1M the part required may be removed | |||
from that position and used." The memorandum further stated that all positions of | |||
an MCC have the same "Q" qualification and a new WRIF was to be generated to | |||
rework the spare position when approved parts became available. | |||
After this memorandum was issued, many work packages contained similar | |||
instructions to remove needed parts from the spare position of an MCC, to | |||
document this removal, and to initiate a WRIF to work the spare position. 3 | |||
However, the inspectors identified a case where the mechanics swapped parts j | |||
between two fused disconnect switches and reinstalled the then-defective parts in i | |||
the spare position (See Section M3.2). This practice of taking parts from a spare | |||
position did not always involve an engineering evaluation and was not controlled by | |||
procedures. | |||
During QA Audit 97-0118, the licensee QA organization identified the same | |||
concern with caanibalizing parts without proper controls in place. Therefore, | |||
, traceability, component storage level, reviews for equivalency, or qualification of | |||
similar parts did not receive adequate QC or Material Engineering review. | |||
The licensee indicated to the inspectors that taking replacement parts from spare | |||
positions was necessary due to the lack of available parts. However, the inspectors | |||
considered the control for this practice lacked forethought before implementation | |||
and lacked proper engineering controls, | |||
c. Conclusion l | |||
l | |||
The inspectors concluded that the current practice of taking replacements parts | |||
from spare MCC positions lacked control and was a weakness in the MCC | |||
replacement parts program. | |||
M8 Miscellaneous Maintenance issues | |||
M8.1 (Open) Violation 50-341/95012-02a: Use of inadequate procedures in performing | |||
electrical maintenance activities. The inspectors reviewed the actions taken on this i | |||
13 | |||
1 | |||
l | |||
__ | |||
1 | |||
T | |||
' | |||
i | |||
. | |||
1 | |||
item. The existing electrical maintenance procedures were to be reviewed by the | |||
licensee for adequacy. The review of these procedures had not been completed. | |||
This item will remain open until the review of the electrical maintenance procedures | |||
has been completed by tha licensee. | |||
M8.2 (Closed) Violation 50-341/95012-02b: The racks and terminals of the station | |||
batteries had deteriorated due to corrosion. In response to the violation, the | |||
batteries and racks were thoroughly cleaned. The inspectors walked down and | |||
observed the material condition of the station batteries. Battery and rack conditions | |||
appeared to be good with only one small spot of corrosion noted. Additional | |||
actions taken included a required weekly walkdown of the batteries. This item is | |||
closed. | |||
M8.3 (Closed) Violation 50-341/95012-04a: Maintenance Procedure 35.309.001 was | |||
inadequate and allowed the connection of a test resistor bank to the batteries | |||
which rendered the batteries inoperable. The inspectors reviewed the changes | |||
l made to the procedure. The changes appeared to be adequate. This item is closed. | |||
! | |||
M8.4 (Closed) Violation 50-341/96013-03: Failure to identify and correct a disconnected | |||
l electricallead. The inspectors reviewed actions taken on the disconnected lead | |||
issue. Procedures controlling the lifting and landing of electricalleads appeared to ! | |||
be adequate. During the observation of maintenance activities, the inspectors | |||
) | |||
i | |||
noted that the control of lifted leads in the field appeared to be good i | |||
(Section M1.1). This item is closed. I | |||
l | |||
lil. Enaineerina | |||
E2 Engineering Support of Facilities and Equipment | |||
E2.1 Proper Lubrication Levels for Rotatino Eouipment | |||
a. Insoection Scooe (3755_0_1 | |||
' | |||
l | |||
The inspectors walked down the EDG 12 following the maintenance work and | |||
before PMT. The generator bearing oil sight glasses had scribed lines in the middle | |||
of the sight glasses. The inspectors found the outboard bearing with the meniscus | |||
just below the scribe line and the inboard bearing oil level at a full '/4 inch below the | |||
scribe line. The system engineer indicated that the proper oil level was % to3 4/ full | |||
on the sight glass. The inspectors questioned the appropriate oil level for providing | |||
adequate lubrication to the bearings, | |||
b. Observations and Findinas | |||
Following discussions with the EDG system engineer, the inspectors reviewed the | |||
i operator round sheets. These sheets also referenced the level as % to8 4/ full for | |||
l the appropriate oil level. However the vendor's manual indicated that the level | |||
l should be maintained at the scribed mark (% position). The license could not | |||
! provide justification for the / level denoted on the round sheet. The licensee | |||
I contacted the vendor but was unable to obtain clear guidance. The inspectors | |||
requested a drawing that would show the bearing internals in relation to the sight | |||
14 | |||
l | |||
l | |||
l | |||
~ | |||
f . | |||
l | |||
, | |||
l. | |||
! glass indication; however, the licensee could not provide the information. The | |||
licensee initiated a DER to address the conflicting information. | |||
In addition, the licensee did not give operators guidance for the correct oil level for | |||
; | |||
' the alternator when the EDG was operating. The vendor's manual specifically | |||
stated, "Do not check the oillevel and do not add oil while the alternator is | |||
running!" However, the inspectors questioned the adequacy of such guidance. The | |||
EDGs are expected to operate continuously for several days during a design basis | |||
accident. Without guidance, operators would have no warning of inadequate oil | |||
levels and therefore allow the bearing to run to failure. | |||
During a plant tour, the inspectors also noted that the high pressure coolant | |||
injection (HPCI) booster pump had simi!ar sight glasses. The operator's round | |||
sheets for HPCI provided no guidance on the proper oillevel either in the standby or | |||
operating condition. The vendor manualindicated normal oillevels should be | |||
maintained but did not say what that level was, in addition, the licensee could not ' | |||
provide drawings of the bearing internals in relation to the sight glass with l | |||
sufficient detail to assure the appropriate oillevel. The inspector was informed that | |||
the operators had been trained during on the-job training as to the appropriate oil | |||
level. However, the licensee could not provide any conclusive information on the | |||
correct level. | |||
The licensee acknowledged that appropriate lubrication levels were not clear and | |||
l | |||
was planning to research the issue further. The licensee indicated the results would i | |||
be incorporated into an existing program. | |||
Understanding of appropriate lubrication levels for rotating equipment was | |||
fundamental in ensuring reliable equipment operation. However, engineering did not | |||
demonstrate that understanding during this inspection. The inspectors consider this | |||
item an unresolved item (URI 50-341/97005-03) pending the licensee's review of | |||
lubricating levels for rotating equipment and inspector review of the licensee's final | |||
, | |||
l | |||
documented guidance to the staff on proper oillevels, | |||
c'. Conclusions | |||
1 | |||
One unresolved item was identified concerning the determination of proper oil level | |||
for rotating equipment. The inspectors concluded that engineering did not have an | |||
adequate understanding of proper lubrication levels for the plant specific equipment. | |||
E2.2 Oil Analysis for Rotatina Eauipment | |||
a. Inspection Scope (37550) | |||
Emergency Diesel Generator 12 had the outboard alternator bearings replaced in | |||
November 1996. The inspectors reviewed the oil analysis that led up to the | |||
, replacement and following the replacement. | |||
i | |||
15 | |||
i | |||
7 | |||
. | |||
. | |||
b, Observations and Findinas | |||
The licensee used oil analysis as a tool to predict future problems with equipment. | |||
A graph of the severe wear indication (SWI) for the outboard alternator bearing | |||
from late 1992 to October 1996 did not show a trend before a significant step | |||
change. Before bearing replacement in November 1996, the graphed data was | |||
scattered with the highest value less then 20,000 and most values less then | |||
, | |||
10,000 SWI. Less then 10,000 SWI was the expected value, in November 1996, | |||
the indication reached 110,000 as a step change and the bearing was changed out. | |||
i | |||
' | |||
' | |||
Following the bearing replacement, the oil analysis for SWI continued to be | |||
' scattered with all but one value above the 10,000 SWI maximum expected value. | |||
The licensee indicated that the higher than-expected values after the bearing | |||
i change were due to break in wear on the bearing; however, the licensee had not | |||
j. contacted the vendor for guidance on how long the break-in period should be. | |||
j During the EDG 12 outage, the bearing oil reservoir was drained and refilled to the | |||
l | |||
i top of the sight glass level, and the engine was rotated two revolutions. Then the | |||
j oil was drained and replaced. The oil sample after the 3-hour post-maintenance | |||
i | |||
testing resulted in an SWI of 12,480. | |||
: | |||
' | |||
The inspectors further noted that the information provided to an independent | |||
[ laboratory performing a separate oil analysis was not complete. The laboratory was | |||
i | |||
1 | |||
not provided with the service timo of the bearing and its oil. Without correlating | |||
the service time of these two factors, the results could be misleading. | |||
' | |||
, | |||
c. Conclusion | |||
: | |||
, | |||
; | |||
The licensee had been monitoring bearing vibrations for the EDG 12 alternator; the | |||
i | |||
data appears satisfactory. However, not knowing the expected break-in period for | |||
, the bearing and not trending the oil analysis with respect to the service time of the | |||
l | |||
bearing and oil raised additional uncertainties concerning the status of the bearing, | |||
j | |||
The inspectors considered this lack of knowledge a weakness in engineering | |||
, | |||
' | |||
support to maintaining the plant. | |||
i, | |||
h E2.3 Inadeauate Enaineerina Evaluation of Parts and Components | |||
I | |||
a. inspection Scope (37550) | |||
' | |||
During the observation of maintenance activities on EDG 12, the inspectors noted | |||
that three parts installed during the maintenance were nonsafety-related. The | |||
- | |||
, inspectors discussed the use of nonsafety-related parts on safety-related equipment | |||
; with the licensee and reviewed engineering evaluations for the three nonsafety- | |||
i related parts used on EDG 12. | |||
! | |||
. | |||
l | |||
> | |||
, | |||
16 | |||
i | |||
F . | |||
. | |||
b. Observations and Findinas | |||
inadeauate Enaineerina Evaluation for Use of Nonsafetv-Related Parts in EDGs | |||
Plant procedures required an engineering evaluation if nonsafety-related parts were | |||
used for the repair or modification of safety-related equipment. The evaluation | |||
would be performed to verify the acceptability of the part to be used. | |||
Engineering evaluations for two of the nonsafety-related parts installed on EDG 12 | |||
on May 13,1997, appeared to be adequate. However, the evaluation for the third | |||
part, a rectangular vegetable fiber gasket used for the turbo charger blower cover | |||
gasket, appeared to be inadequate. The engineering evaluation checklist for the | |||
evaluation, dated August 2,1989, indicated that the gasket did not perform a | |||
critical function and would not fail. However, the inspectors disagreed with this | |||
conclusion. The possibility of causing significant operational problems appeared to | |||
exist if the gasket failed. In addition, five questions were inappropriately marked | |||
"NA" and the required justifications were not included for answers to the questions | |||
on the form. | |||
10 CFR 50, Appendix B, Criterion Ill, " Design Control," required that measures be | |||
established for the selection and review for sui *sbility of application of materials, | |||
parts, equipment and processes that are essential to the safety-related functions of i | |||
structures, systems and components. The installation of the nonsafety-related I | |||
turbo charger blower cover gasket on safety-related EDG 12 without performing an I | |||
adequate engineering evaluation which addressed the suitability of application of | |||
the parte to the safety-related functions of the EDGs is an example of a violation of | |||
10 CFR 50, Appendix B, Criterion 111 (VIO 50-341/97005-04a). | |||
1 | |||
The inspectors identified this problem to the licensee personnel and management | |||
l | |||
during several discussions. During the discussions of this problem, licensee | |||
l | |||
personnel stated that DER 96-0903 had been written on inadequate justifications l | |||
for engineering evaluations on August 7,1996. The action taken on the DER | |||
' | |||
appeared to be limited to enhancement of the evaluation criteria and did not | |||
address reevaluation or control of parts which were previously inadequately l | |||
evaluated. The inspectors noted that the DER stated, "This is a weakness, not a | |||
serious problem." | |||
The action taken on DER 96-0903 to correct the problem of weak evaluations for | |||
using nonsafety-related parts in safety-related applications was inadequate. In | |||
addition the previously identified deficient evaluation for the gasket was not | |||
corrected. As a result, the licensee continued to install similar gaskets in EDG 13 | |||
on May 20 and in EDG 14 on May 27, without further evaluations. Until a proper | |||
engineering evaluation is completed, it is not known if these gaskets would affect | |||
the operation of the three EDGs. | |||
Even though DER 96-0903 was written on this problem on August 7,1996, no | |||
actions were taken to verify the adequacy of engineering evaluations prior to use of | |||
nonsafety-related parts and no controls were in place to prevent the installation of | |||
inadequately evaluated nonsafety related parts. As a result, inadequately evaluated | |||
nonsafety-related parts continued to be used in safety-related equipment until at | |||
17 | |||
' | |||
( . | |||
. | |||
least May 27,1997. This is an example of a violation of Criterion 111(50- | |||
341/97005-04B(DRS)). | |||
Generic Justification for Use of Parts in Plant Eauipment | |||
The licensee has assigned a generic plant identification system (PIS) number for | |||
ordering expendable items such as rags, cleaners, etc. Licensee personnel stated | |||
that this PIS number was not intended for parts used in plant equipment. The | |||
licensee identified that plant personnel had inappropriately used this generic PIS | |||
number to order nonsafety-related parts to be installed in the plant. The licensee | |||
indicated that the root cause appeared to be a lack of knowledge of the purpose of | |||
this PIS number. In other cases, personnel appeared to use this PlS number to | |||
avoid required engineering evaluations for nonsafety-related parts. The licensee | |||
stated that additional training was to be provided to maintenance personnel. In | |||
addition, a memorandum was issued by the Plant Manager to clarify the use of | |||
generic PIS numbers and ensure that engineering evaluations would be performed | |||
l | |||
when needed. Licensee action on this problem appeared to be adequate. | |||
1 | |||
c. Conclusions | |||
One violation with two examples was identified concerning poor design control for l | |||
use of nonsafety-related parts in safety-related systems. Material control practices l' | |||
appeared to be weak. Some engineering evaluations, allowing the use of | |||
nonsafety-related parts in safety-related equipment, were inadequate. In addition, | |||
licensee personnel had found ways to bypass the entire process. The emphasis l | |||
appeared to be on expediting work without significant concern about the integrity | |||
of replacement parts. l | |||
In using nonsafety-related gaskets on EDGs, the licensee appeared to be slow in | |||
responding to the concern and providing addit.:onal evaluations. | |||
E8 Miscellaneous Engineering issues | |||
E8.1 LClosed) Violation 50-341/95003-03: Use of unapproved material on safety-related | |||
equipment. This violation was written for using non-approved cleaners and | |||
lubricants in electrical applications. The inspectors reviewed procedure | |||
35.000.217, " Maintenance Lubrication," Revision 28, and other actions taken to | |||
ensure that only approved lubricants and cleaners were used to clean and lubricate | |||
safety related components. Actions taken included a prohibition on the use of | |||
Cramolin, a known non qualified contact cleaner. During the observation of | |||
maintenance activities the inspectors noted thet only approved cleaners and | |||
lubricants were used. This item is closed. | |||
18 | |||
F ! | |||
. | |||
. | |||
V. Manaaement Meetinas | |||
X1 Exit Meeting Summary | |||
The inspectors presented the inspection results to members of licensee management at the | |||
conclusion of the inspection on May 30,1997. The licensee acknowledged the findings | |||
presented. | |||
The inspectors asked the licensee whether any materials examined during the inspection | |||
should be considered proprietary. No proprietary information was identified. | |||
! | |||
l | |||
l | |||
l | |||
6 | |||
19 | |||
_ -. . . . . | |||
. . - . .- - . . - | |||
I, I | |||
! | |||
. | |||
' | |||
' | |||
PARTIAL LIST OF PERSONS CONTACTED | |||
Licensee | |||
S. Booker, General Supervisor, Electrical Maintenance | |||
l P. Borer, Vice President | |||
l D. Cobb, Superintendent, Operations | |||
R. Cook, Acting Supervisor, Compliance | |||
M. Caragher, Supervisor, Material Engineering | |||
R. Delong, Superintendent, System Engineering , | |||
P. Fessler, Plant Manager, Operations i | |||
D. Gipson, Senior Vice President, Generation | |||
! J. Green, Maintenance Superintendent, Maintenance Support ) | |||
l J. Hughes, Supervisor, inspection and Surveillance, QC 1 | |||
j' R. Matthews, Maintenance Superintendent l&C ' | |||
N. Peterson, Acting Director, Licensing | |||
K. Sessions, Work Control | |||
, | |||
' | |||
: T. Schehr, Engineer, Operations | |||
' | |||
R. Wittschen, Compliance Engineer | |||
. | |||
, | |||
NRC l' | |||
l | |||
G. Harris, Senior Resident inspector , | |||
N. O'Keefe, Resident inspector | |||
[ | |||
i | |||
. | |||
: | |||
l | |||
20 | |||
i | |||
1 | |||
. | |||
INSPECTION PROCEDURES USED | |||
IP 37550: Engineering | |||
IP 62703: Maintenance Observatim | |||
ITEMS OPENED, CLOSED, AND DISCUSSED | |||
Opened | |||
50-341/97005-01 VIO failure to maintain DFP engine speed within acceptable | |||
operating limits and to perform adequate PMT | |||
50-341/97005-02 VIO failure to have approved instructions prior to performing | |||
maintenance on a spare disconnect switch | |||
G0 341/97005-03 URI licensee review of lubricating levels for rotating equipment | |||
50-341/97005-04 VIO inadequate engineering evaluation of nonsafety-related parts | |||
Closed | |||
50-341/95003-03 VIO use of unapproved material on equipment | |||
50-341/95012-02b VIO deterioration of station batteries | |||
50-341/95012-04a VIO inadequate procedure rendered a station battery in inoperable | |||
50-341/95012-04b VIO inadequate procedure placed a station battery in service before | |||
maintenance was completed | |||
' | |||
50-341/96013-03 VIO failure to identify and correct a disconnected electrical lead | |||
Discussed | |||
50-341/95012-O'2a VIO use of inadequate procedures in performing electrical | |||
maintenance activitics | |||
. | |||
: | |||
l | |||
l | |||
l 21 | |||
. | |||
_ . _ . _ . . _ . _ . _ _ _ . _ . . . . . _ _ _ _ - . _ _ _ . . _ _ _ _ . _ . | |||
> | |||
. | |||
LIST OF ACRONYMS USED | |||
l | |||
CFR Code of Federal Regulations | |||
CCHVAC Control Room Heating l Ventilation and Air Conditioning | |||
CS Core Spray | |||
DECO Detroit Edison Company | |||
DER Deviation Event Report | |||
DFP Diesel Fire Pump | |||
DRS Division of Reactor Safety | |||
EDG Emergency Diesel Generator | |||
FME Foreign Material Exclusion | |||
HPCI High Pressure Coolant injection ' | |||
l l&C Instrumentation and Control | |||
M&TE Measurement and Test Equipment l | |||
MCC Motor Control Center | |||
MMA Maintenance Conduct Manual | |||
NRC Nuclear Regulatory Commission | |||
i NSS Nuclear Shift Supervisor | |||
l NUREG Nuclear Regulatory Guide | |||
PDR Public Document Room 1 | |||
PMT Post-Maintenance Testing | |||
l QA Quality Assurance | |||
SWI Severe Wear Indication 1 | |||
TIR Total Indicated Runout b | |||
TS Technical Specification I | |||
TWMS Torus Water Management System | |||
URI Unresolved item | |||
VIO Violation | |||
W RIF Work Request initiation Form | |||
l | |||
! | |||
. | |||
l | |||
l | |||
! | |||
! | |||
! | |||
l | |||
i | |||
. | |||
J | |||
, | |||
22 | |||
l | |||
, | |||
l_. | |||
}} |
Latest revision as of 21:09, 7 August 2022
ML20148N147 | |
Person / Time | |
---|---|
Site: | Fermi ![]() |
Issue date: | 06/19/1997 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20148N136 | List: |
References | |
50-341-97-05, 50-341-97-5, NUDOCS 9706260127 | |
Download: ML20148N147 (22) | |
See also: IR 05000341/1997005
Text
_ . . _ . . _ , . . _ . _____
I '
l
l'
I
i
- U.S. NUCLEAR REGULATORY COMMISSION
REGION lll
'
4
-
Docket No: 50-341 !
License No: NPF-43 1
l
Report No: 50-341/97005(DRS)
Licensee: Detroit Edison Company
Facility: Enrico Fermi, Unit 2
i
,
l Location: 6400 N. Dixie Highway
j Newport, MI 48166
!
i
Dates: May 12 through May 30,1997
Inspectors: M. Miller, Reactor Engineer
D. Chyu, Reactor Engineer
H. Walker, Reactor Engineer
Approved by: Mark Ring, Chief, Lead Engineers Branch
j , Division of Reactor Safety
!
,
l
I
d
9706260127 970619 '
PDR ADOCK 05000341
G pm -,
i
4
.
EXECUTIVE SUMMARY
l
Enrico Fermi, Unit 2
NRC Inspection Report 50-341/97005(DRS)
1
l This inspection included aspects of licensee maintenance and engineering. The purpose
!
of the inspection was to assess the conduct and control of your surveillance and
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maintenances activities. The enclosed report presents the results of that inspection.
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Maintenance
The emergency diesel generator 12 outage showed the licensee's ability to plan and
execute a maintenance activity in a controlled and efficient manner (Section M1.1).
The corrective actions to control measurement and test equipment (M&TE) have
had positive results in resolving past problems with delinquent return of equipment
and with delayed evaluation of the effects on equipment tested with M&TE that
failed as-found calibrations (Section M1.2).
One violation with two examples was identified concerning poor control of
surveillance and post-maintenance testing on the diesel fire pump (Section M1.3). I
The use of the licensee's minor maintenance program called, " Tool Pouch
Maintenance," on fused disconnect switches resulted in the lack of documentation
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for repetitive failures of the switches (Section M1.4).
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The inspectors identified three exemples and one violation of workin0 outside the
work scope or a lack of documentation of work performed in the field. In addition,
muitiple barriers such as the electrical maintenance personnel, their supervisors, and
a quality control (OC) inspector failed to identify this violation (Section M3.2).
One weakr ess was identified for a lack of procedural control for cannibalizing parts
from spare motor control center (MCC) positions when spare parts were not
available from the warehouse (Section M6).
Enaineerina
The engineering recommendation to not declare the diesel fire pump inoperable
based on calculations which indicated the pump could fail the flow requirements at j
low speed was non-conservative and lacked proper focus on equipment operability ]
(Section M1.3).
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Engineering personnel dM not demonstrate a clear understanding of proper '
lubrication levels for plant specific equipment. One unresolved item was identified
concerning the determination of proper oillevel for rotating equipment ;
(Section E2.1). j
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The inspectors noted several weaknesses in engineering support for maintaining the
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plant. These weaknesses were: not knowing the expected break-in period for the !
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EDG alternator bearings and not trending the oil analysis with respect to the service
time of the bearing and its oil (Section E2.2).
One violation was identified concerning inadequate design control for nonsafety-
related parts used in safety-related systems. The licensee's response to material
control issues appeared to be slow (Section E2.3).
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Report Details
1. Operations
08 Miscellaneous Operations issues
08.1 (Closed) Violation 50-341/95012-04b: Operations Conduct Manual MOPOS,
"Cuntrol of Equipment,". was inadequate and was a contributor to a station battery
problem. A battery charger was placed in service before maintenance and testing
of the batteries had been completed. The inspectors reviewed Revision 5 of the
manual and considered the changes to address this issue to be adequate. This item
is closed,
11. Maintenance
M1 Conduct of Maintenance
M 1.1 Emeraency Diesel Generator (EDG) 12 System Outaae
a. Inspection Scope (62702
The inspectors observed ail or portions of the following work activities associated
with the EDG outage and reviewed some completed work packages:
- 000Z954038 Oilleaking from coupling and instrument
- 000Z955261 Replace air receiver drain valve
000Z961121 Repair headshaft sleeve that has moved upwards
- 000Z961758 Investigate noise coming from muffler internals
e 000Z962346 EDG-12 fan is out of balance
- 000Z967890 Flush inboard and outboard bearings
- 000Z971260 Fuse 1 and 2 were noted to have loose clip i . Dase
assembly
- 000Z973910 Replace gasket and washers on blower
- R295940706 Electrically test time delay relay
- R398940624 Inspect / test 480 volt motor control center (MCC)
- R605960311 EDG 12 motor operated controlinspection
- R609960311 Perform EDG 12 motor operated potentiometer
inspection
- S979940725 Recalibration of EDG 12 standby heater discharge
control temperature switch
i switches
) * X895960315 X4103C003 - Inspect / test MCC, check fan, lobe motor
l * X899960315 X4103C004 - Inspect / test MCC, check fan, lube motor
b. Observations and Findinas
The inspectors observed pre-job briefings in the electrical, mechanical, and
instrumentation and control shops. Each supervisor used a checklist to ensure that
management expectations for the pre-job briefing were addressed. Supervisors
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and were able to answer the worker's questions. Most workers appeared to have
walked the jobs down before the briefings.
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Supervision was present and actively involved with the workers at the job site. The
major challenge to supervision was to ensure that the critical jobs were given
priority when space conflicts existed. Overall coorciaation of the EDG 12 work
activities was efficient and controlled.
The inspectors observed the use of measurement and test equipment (M&TE) for
the work activities. The equipment was properly checked out for the specific jobs,
was within the specified calibration period, and was returned appropriately to the
M&TE crib. Workers appeared knowledgeable about the proper use of the test
equipment. This issue is further discussed in Section M1.2.
The inspectors observed the use of the interim alteration checklist in documenting
the lif ting and landing of electricalleads. The inspectors specifically noted that the
checklists were filled out as the work progressed. Through direct observation,
periodic checks, and review of completed work documents, the inspectors
concluded that the interim alteration checklist was being used properly.
Although the outage did not require any significant foreign material exclusion (FME)
controls, the inspectors observed proper use of FME techniques for the jobs
requiring some form of control.
c. Conclusions
The licensee expended significant effort in planning the activity and the results
were good. Pre-job briefings were good and appeared to benefit from the use of a
checklist. Supervision was present at the work site and provided useful input to
personnel. Maintenance personnel showed clear capability to perform the tasks
efficiently.
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The EDG outage showed the licensee's ability to plan and execute a maintenance
activity in a controlled and efficient manner.
M1.2 Control of Measurement and Test Eauipment
a. Insoection Scope (62703)
The inspectors reviewed the use of M&TE because of previous problems identified
in inspection Report 50-341/95008, Section 6.1.2. The scope included looking for
equipment remaining in the field beyond the time allowed, M&TE being used on
activities that the M&TE was not checked out for, and the ability to track where
specific M&TE was used, when a calibration failed.
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b. Observations and Findinas
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The inspectors examined the signout documents for specific M&TE used for the
EDG 12 outage, in each case, the M&TE was appropriately signed out for the
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correct job and returned following the work. The inspectors examined records of
other equipment and interviewed the attendant for the tool crib. The
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documentation for M&TE appeared to track the use of the equipment appropriately.
The licensee had recently implemented corrective actions for delinquent returns of
M&TE. The new practice was to perform a weekly audit for delinquent equipment
- and contact the supervisors of the persons responsible for the delinquent
equipment. A one-day grace period was allowed for returning the M&TE. If the l
equipment was not returned that day, the responsible person would lose his or her l
privilege to check out any other M&TE until the delinquent equipment was returned.
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The policy appeared to reduce the problem with delinquent equipment significantly. !
Another recent change addressed control of M&TE when an "as found" calibration
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failed. Once M&TE failed a calibration, all plant equipment serviced by the suspect
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M&TE needed to be evaluated to determine the effect of the calibration failure. The
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licensee had been writing a single deviation event report (DER) for each failure and
requiring each work group to address the particular work packages associated with
the M&TE. The single DER provided little accountability and resulted in delajed
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' evaluations. The licensee changed the method to writing a separate DER for each
work group that used the failed M&TE. This resulted in an increased number of
DERs associated with M&TE calibration failures but increased the accountability and
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timeliness of addressing the effect on plant equipment.
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c. Conclusions
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The changes made to control M&TE have had positive results in resolving past I
problems. No problems were identified during this inspection. Delinquent M&TE
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was significantly reduced to an occasional single person having his or her privileges
I suspended. The licensee recently had an 11-week period where no one had
privileges suspended.
M1.3 Inadeauate Testina of the Diesel Fire Pumo Followina Maintenance
l a. Inspection Scope (62703)
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During a review of Work Request 000Z975065, the inspectors noted that the diesel
fire pump (DFP) speed had been lowered; however, the post-maintenance testing
(PMT) did not address the resultant change in discharge pressure and water flow.
The inspectors reviewed previous flow testing results and licensee actions to
address the issue.
b. Observations and Findinas I
j' The inspectors reviewed the work request written to correct a deficiency with the
l- diesel tripping on over speed. The work was signed off as satisfactory on May 11,
! 1997. The inspectors noted that part of the corrective actions was to lower the ;
l diesel speed from 2440 rpm to 2150 rpm. The inspectors questioned the effect on l
- the fire pump flow and whether the current flow test would be invalidated. The l
- inspectors also noted that the nuclear shift supervisor (NSS) had raised questions
- concerning the effects of lowering the speed on the pump flow test. The NSS's
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concern was documented in the work package and then lined out without any
documented reason. The PMT was to perform a DFP weekly surveillance during ,
which only the discharge pressure was monitored. '
The licensee initiated a DER on May 27, in response to the inspector's questions,
initial calculation by engineering suggested that the flow test could potentially fail
! with lower engine speed. However, the DER stated, "This corrected data is
theoretical and may vary from actual measured data. This data should not be used
to classify the diesel fire pump as inoperable. Performing a flow test at the current
engine speed will determine operability." The on-duty NSS reviewed the DER and
declared the dieselike pump inoperable and entered th9 limiting condition for
operation.
On May 28, the licensee performed Fire Protection Procedure 28.504.003, " Fire
Suppression Water System Simulated Auto Actuation Test," three times over a 12-
hour period. The last attempt was successful. The acceptance criteria required a
discharge pressure between 114.4 and 93.6 psig and the flow between 3375 and
4125 gpm. The final test results had the discharge pressure at 94 psig and the l
flow at 3407 gpm. Followi the satisfactory test, the licensee raised the diesel l
speed to a band of 2250 to & , 7 rpm and succes*lly performed the surveillance
again.
Technical Specification (TS) 6.8.1 required that procedures covering the Fire l
Protection Program shall be established, implemented, and maintained. The Detroit
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Edison Maintenance Conduct Manual, MMA11, " Post-Maintenance Testing
Guidelines," defined one criterion of satisfactory PMT as one that ensured no new
or related deficiencies had been created by maintenance work. Following the
maintenance work which changed a speed sensor switch, the diesel engine speed
was also reduced. The PMT following the maintenance did not adequately address
the effect of lowering the engine speed. Failure to properly test the DFP following i
maintenance is an example of a violation of TS 6.8.1 (VIO 50-341/97005-01a). l
, The inspector reviewed a previously completed DFP flow test 28.504.003
(completed May 2,1997) and noted the diesel speed was outside the acceptable
limits based on the use of a strobe tachometer. The diesel speed was recorded as
2440 rpm with the neceptable limits being 2100 to 2300 rpm. A note was entered
on a discrepancy / resolution form stating that the installed tachometer was
inoperative. No change was made to the procedure to allow the use of the strobe
tachometer in piace of the installed engine tachometer and no justification was
provided for accepting the out-of-limit engine speed. The section of the
surveillance was signed off as satisfactory with the pump pressure at 114 psig and
the flow at 3855 gpm.
The test procedure noted that the fire pump pressure and flow were acceptance
criteria but the procedure did not designate the diesel speed range as an acceptance
criterion. However, the increased engine speed directly affected the pump
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discharge pressure and flow acceptance criteria as demonstrated by the May 28
testing. The licensee failed to recognize the significance of the over speed
condition and inappropriately accepted the test as valid. This is considered another
example of a violation of TS 6.8.1 (VIO 50-341/97005-01b).
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c. Conclusions
The inspectors identified an example of poor control of a surveillance procedure and
an example of inadequate post-maintenance testing. The licensee appeared to
focus on. passing the tect rather than ensuring the equipment could perform its
required function. The inspectors noted weaknesses in the licensee's review of
completed packages and in the questioning attitude of multiple organizations. The
entire problem with the fire pump could have been avoided by a critical review of
the surveillance performed on May 2. ,
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Engineering's recommendation not to declare the DFP inoperable based on the
calculation appeared non-conservative. The non-conservative decision making by
engineering was further amplified by the extensive efforts necessary to pass the
surveillance at the lower engine speed and the small margin with which it passed.
Operations promptly recognized the problem with the DER and appropriately
declared the DFP inoperable until the test proved otherwise.
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M1.4 Tool Pouch Maintenance
a. Inspection Scope (6703) j
The inspectors reviewed the minor maintenance program called " tool pouch
maintenance." This review included a review of the controlling procedure and
discussions of the program with licensee personnel.
b. Observations and Findinas
During discussions with licensee personnel on problems with the fused disconnect
switches in the ITE 480 volt MCCs, licensee personnel stated that maintenance
assistance provided to operators in the closing of the MCC fused disconnect
switches included cleaning and lubricating the fused disconnect switches. They
further stated that these actions were appropriately covered under the " tool pouch
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maintenance" program.
l The inspectors reviewed Section 3.4.2 of MMA02, " Maintenance Program,"
I Revision 1, which described " tool pouch maintenance." Enclosure "B" of the
procedure listed four pages of examples of work to be performed under the tool
pouch maintenance program. This list, which was not all inclusive, did not list
minor cleaning and lubrication. Since this type of work was not listed, there was
some question about whether or not it should be included. The uses of tool pouch
maintenance on fused disconnect switches resulted in the lack of documentation
for repetitive failure of these switches. Therefore, the extent of the problem was
l initially characterized incorrectly and was not considered significant. In addition,
j the licensee erroneously considered that the inability to manually close the switches
was not a failure of the switches,
t c. Conclusions
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- The use of " tool pouch maintenance" may be inappropriate for safety-related or
{ important nonsafety-related equipment. Since records of this maintenance were
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not normally prepared and retained, repetitive problems could be incurred without !
the knowledge of plant management, systems engineers or other personnel. The
inspectors concluded " Tool pouch maintenance" would be inadequate for
equipment or systems covered by the Maintenance Rule unless adequate controls
were in place to ensure documentation and trending of repetitive equipment
problems.
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j M3 Maintenance Procedures and Documentation
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M3.1 Lack of Documentation of Work Performed
I a. Inspection Scope (62703)
The inspectors reviewed work request (WR) package 000Z965287, " Torus Water
- Management Recirculation Line Isolation Valve Rework," and identified one example
where the documentation of work performed in the work packages was unclear.
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The inspectors also interviewed various licensee personnel and identified that
i electrical maintenance personnel were assisting operations in closing electrical
l disconnect switches without approval or documentation in work packagcc.
4 b, Observation and Findinas
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The inspectors identified an example of weak documentation of work gedormed in
WR 000Z965287. The mechanics performed blue checks on the old and new valve
discs for valve G5100F609. The mechanics documented an unsatisfactory blue
! check on the new disc, but a satisfactory blue check on the old disc. However, the
! documents did not specify which valve disc was put back in the valve. The .
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inspectors interviewed the supervisor who indicated that the old disc was put back
in the valve because the blue check was satisfactory.
In addition, licensee personnel indicated to the inspector that when operators could
not manually close fused disconnect switches, electrical maintenance personnel
, were requested to assist in the closure of the switches. The assistance involved
lubricating the switches and sometimes pushing the switches closed with fuse
pullers. However, the lubrication activities were neither authorized nor documented
in any work packages. The inspectors did not identify any actual examples of this
practice in the field.
M3.2 Work Performed Outside the Packaae Scope
a. Inspection Scoce (62703)
The inspectors reviewed the followina packages:
- 000Z965287- Torus water management recirculation line isolation
valve rework
- 000Z971595 Temperature switch electric: Control Room Heating,
Ventilation and Air Conditioning (CCHVAC) chiller
compressor unit oil temperature
- 000Z958122 Fire protection diesel fire pump
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- 000Z970741 Fire protection diesel fire pump
- 000Z965876 Fire protection electrical driven fire pump outlet check
valve
- 000Z974392 MCC for torus water management system (TWMS)
return to CS outboard isolation valve
- 000Z961484 480 Volt motor control center No. 72C-2A
- 000Z974393 Control rod drive pump room cooler
- 000Z964774 CCHVAC emergency air north intake division 2 isolation
b. Observations and Findinas
Straiahtenina a Bent Valve Stem for a Nonsafetv-Related Valve Without Aporoved
Work Packaae l
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During the review of WR 000Z965287, the inspectors identified that a new valve l
stem staged for valve G5100F609 rework was found bent and the mechanics
straightened it without approved instructions in line packages. Mechanics were
trained to check total indicated runuut (TIR) on new valve stems before installing
them. The mcchartics identified that the TIR on the new stem was not within the
specification of less than or equal to .0055 inches per foot. The mechanics then
straightened the new stem, recorded the new TIR on the new stem, and put it in
the valve. Although this action was documented in the package, straightening of
the bent valve stem was not within the scope of the package.
Work on a Safetv-Related Soare Switch Without Approved Work Packaae
After restoring MCC 72E 5A Position 3C for TWMS return to residual heat removal
outboard isolation valve, the MCC switch opened unexpectedly when an operator
was closing the door. The switch was reclosed and remained closed. Due to this
problem, on April 24,1997, electrical maintenance personnel performed
- maintenance on the fused disconnect switch using Work Request OOOZ974256.
After cleaning and lubricating the switch, the operation of the switch was
unsatisfactory. The package was revised on April 25 to troubleshoot and replace
necessary parts on the switch. On April 28, the electrical maintenance personnel
swapped the folk, wing parts between MCC 72E-5A Positions BC (a spare fused
disconnect switch) and 3C: the rotary switch, the lower fuse block, and the
electrical disconnect switch. Following the swap, both switches failed after
cleaning and lubricating. On April 29, electrical maintenance personnel recleaned,
relubricated, and exercised the switch mechanisms. Both switches operated
satisfactorily.
The work package was initially revised to reflect using parts from the spare fused
disconnect switch at Position SC; however, some activities were performed beyond
the scope of the package as follows:
Placing the defective parts from MCC 72E-5A Position 3C back into the
spare fused disconnect switch,
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Cleaning and lubricating the spare fused disconnect switch which now
contained defective parts from MCC 72E 5A Position 3C, and
Exercising the spare fused disconnect switch to ensure smooth operation of
the switch.
in addition, Step 7 of the work request package required that if spare parts were
not available from the warehouse, personnel were to r$: move needed parts from the
spare position of the MCC, document the action in the work request, and initiate a
work request initiation form (WRIF) to work the spare position when parts were
returned after refurbishment. However, on April 28, after the parts were removed
from the spare position, maintenance personnel failed to initiate a WRIF for the
spare position and performed work on the spare position without approved
instructions.
The inspectors were concerned this condition of working beyond the initial scope of
the work request and failure to follow the work package were not recognized by the
involved maintenance personnel, their supervisors, and the quality control (QC)
inspector. Although the first QC inspector did not observe swapping of the parts
between the switches, a second QC inspector during the package closecut review,
did not recognize that the maintenance personnel had worked outside the scope of ;
the package. The licensee did not recognize the inappropriateness of working on j
the spare fused disconnect switch until prompted by the inspectors.
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10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"
required, in part, that activities affecting quality shall be prescribed by documented
instructions, procedures, or drawings, of a type appropriate to the circumstances !
and shall be accomplished in accordance with these instructions, procedures, or
drawings. Failure to have appropriate instructions or procedures for performing
maintenance on the MCC 72E-SA Position SC is a violation of 10 CFR 50, l
Appendix B, Criterion V (VIO 50-341/97005-02).
M3.3 Conclusions on Maintenance Procedures and Documentation
The inspectors identified four examples where activities were performed outside the
scopes of the work packages or where work documentation lacked detail. The four
examples were:
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A lack of documentation in the use of a valve disc in the torus water
management system,
A lack of documentation for lubrication and manual assistance of closing
electrical disconnect switches,
Straightening a bent valve stem which was beyond the initial work
instruction, and
Performing maintenance on a spare fused disconnect switch which was
beyond the scope of the work package for repairs of another switch.
A violation of 10 CFR 50, Appendix B, Criterion V, was identified for the last
l example. The inspectors randomly sampled 15 work packages and identified
- deficiencies with three work packages (Two packages were discussed in this
section and the third package was discussed in Section M1.3). The inspectors
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were concerned that 20 percent of the sampled packages contained errors or
violations not previously identified by multiple Detroit Edison personnel.
The inspectors concluded that work documentation in selected packages was poor
because the packages were not stand alone documents and did not contain
sufficient detail for work performed in the field.
M3.4 Procedural Detail and Skill of the Craft
a. Insoection Scope (62703)
The inspectors observed work activities and noted cases where the work results did
not match what was expected. 1
b. Observations and Findino3
Following the EDG 12 outaga the inspectors noted that the oil levels for the
alternator bearing were below the scribed line on the sight glass. The licensee
indicated that the oil had been appropriately filled but had settled after a few hours.
This was due to the high visccsity of the oil. The work request neither provided ,
guidance on the appropriate level to fill the oil nor did it warn the mechanics to
return later and recheck the oil level. l
During the DFP flow testing, the inspectors noted personnel using a strobe !
tachometer to determine the speed of the fire pump. The individual did not notice l
that the readinq obtained was twice the speed that was expected. When the
inspector ques, ioned the value, the individual confirmed the reading with another
strobe tachometer and documented the value. Later the system engineer pointed
out that the strobe was flashing twice for each revolution. The correct reading was
obtained and the correction was entered into the test procedure.
During work on EDG 13, an instrument technician increased the frequency too
quickly during testing of a tachometer and he obtained and recorded the wrong
value. During a second attempt, the frequency was increased more slowly and the
correct value was obtained. There was no guidance to instruct the technician to I
increase the frequency slowly and the technician demonstrated a need for such
guidance.
c. Conclusion
The licensee appeared to depend on the skill of the craft and minimized specific
guidance in the procedures, in these three examples the procedures were weak
and did not contain adequate guidance for the skilllevel of the assigned craft
personnel.
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M6 Maintenance Organization and Administration !
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M6.1 Lack of Control for MCC Replacement Parts
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a. Inspection Scope (6270_3_1
The inspectors and the licensee quality assurance (QA) organization identified a lack 1
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of control for MCC parts replacement. The inspectors reviewed WR 000Z974256;
DER No. 970875, dated May 28,1997, for QA Audit No. 97-0118; and Nuclear
Generation Memorandum NPSC 97-0031. I
b. Observations and Findinas
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On April 25,1997, in response to a recent problem with MCCs, the licensee issued
a memorandum delineating an alternative method to obtain MCC replacement parts.
It stated that, "if the required parts are not available from the warehouse and there
is a spare MCC position which is also Q or Q1M the part required may be removed
from that position and used." The memorandum further stated that all positions of
an MCC have the same "Q" qualification and a new WRIF was to be generated to
rework the spare position when approved parts became available.
After this memorandum was issued, many work packages contained similar
instructions to remove needed parts from the spare position of an MCC, to
document this removal, and to initiate a WRIF to work the spare position. 3
However, the inspectors identified a case where the mechanics swapped parts j
between two fused disconnect switches and reinstalled the then-defective parts in i
the spare position (See Section M3.2). This practice of taking parts from a spare
position did not always involve an engineering evaluation and was not controlled by
procedures.
During QA Audit 97-0118, the licensee QA organization identified the same
concern with caanibalizing parts without proper controls in place. Therefore,
, traceability, component storage level, reviews for equivalency, or qualification of
similar parts did not receive adequate QC or Material Engineering review.
The licensee indicated to the inspectors that taking replacement parts from spare
positions was necessary due to the lack of available parts. However, the inspectors
considered the control for this practice lacked forethought before implementation
and lacked proper engineering controls,
c. Conclusion l
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The inspectors concluded that the current practice of taking replacements parts
from spare MCC positions lacked control and was a weakness in the MCC
replacement parts program.
M8 Miscellaneous Maintenance issues
M8.1 (Open) Violation 50-341/95012-02a: Use of inadequate procedures in performing
electrical maintenance activities. The inspectors reviewed the actions taken on this i
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item. The existing electrical maintenance procedures were to be reviewed by the
licensee for adequacy. The review of these procedures had not been completed.
This item will remain open until the review of the electrical maintenance procedures
has been completed by tha licensee.
M8.2 (Closed) Violation 50-341/95012-02b: The racks and terminals of the station
batteries had deteriorated due to corrosion. In response to the violation, the
batteries and racks were thoroughly cleaned. The inspectors walked down and
observed the material condition of the station batteries. Battery and rack conditions
appeared to be good with only one small spot of corrosion noted. Additional
actions taken included a required weekly walkdown of the batteries. This item is
closed.
M8.3 (Closed) Violation 50-341/95012-04a: Maintenance Procedure 35.309.001 was
inadequate and allowed the connection of a test resistor bank to the batteries
which rendered the batteries inoperable. The inspectors reviewed the changes
l made to the procedure. The changes appeared to be adequate. This item is closed.
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M8.4 (Closed) Violation 50-341/96013-03: Failure to identify and correct a disconnected
l electricallead. The inspectors reviewed actions taken on the disconnected lead
issue. Procedures controlling the lifting and landing of electricalleads appeared to !
be adequate. During the observation of maintenance activities, the inspectors
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noted that the control of lifted leads in the field appeared to be good i
(Section M1.1). This item is closed. I
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E2 Engineering Support of Facilities and Equipment
E2.1 Proper Lubrication Levels for Rotatino Eouipment
a. Insoection Scooe (3755_0_1
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The inspectors walked down the EDG 12 following the maintenance work and
before PMT. The generator bearing oil sight glasses had scribed lines in the middle
of the sight glasses. The inspectors found the outboard bearing with the meniscus
just below the scribe line and the inboard bearing oil level at a full '/4 inch below the
scribe line. The system engineer indicated that the proper oil level was % to3 4/ full
on the sight glass. The inspectors questioned the appropriate oil level for providing
adequate lubrication to the bearings,
b. Observations and Findinas
Following discussions with the EDG system engineer, the inspectors reviewed the
i operator round sheets. These sheets also referenced the level as % to8 4/ full for
l the appropriate oil level. However the vendor's manual indicated that the level
l should be maintained at the scribed mark (% position). The license could not
! provide justification for the / level denoted on the round sheet. The licensee
I contacted the vendor but was unable to obtain clear guidance. The inspectors
requested a drawing that would show the bearing internals in relation to the sight
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! glass indication; however, the licensee could not provide the information. The
licensee initiated a DER to address the conflicting information.
In addition, the licensee did not give operators guidance for the correct oil level for
' the alternator when the EDG was operating. The vendor's manual specifically
stated, "Do not check the oillevel and do not add oil while the alternator is
running!" However, the inspectors questioned the adequacy of such guidance. The
EDGs are expected to operate continuously for several days during a design basis
accident. Without guidance, operators would have no warning of inadequate oil
levels and therefore allow the bearing to run to failure.
During a plant tour, the inspectors also noted that the high pressure coolant
injection (HPCI) booster pump had simi!ar sight glasses. The operator's round
sheets for HPCI provided no guidance on the proper oillevel either in the standby or
operating condition. The vendor manualindicated normal oillevels should be
maintained but did not say what that level was, in addition, the licensee could not '
provide drawings of the bearing internals in relation to the sight glass with l
sufficient detail to assure the appropriate oillevel. The inspector was informed that
the operators had been trained during on the-job training as to the appropriate oil
level. However, the licensee could not provide any conclusive information on the
correct level.
The licensee acknowledged that appropriate lubrication levels were not clear and
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was planning to research the issue further. The licensee indicated the results would i
be incorporated into an existing program.
Understanding of appropriate lubrication levels for rotating equipment was
fundamental in ensuring reliable equipment operation. However, engineering did not
demonstrate that understanding during this inspection. The inspectors consider this
item an unresolved item (URI 50-341/97005-03) pending the licensee's review of
lubricating levels for rotating equipment and inspector review of the licensee's final
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documented guidance to the staff on proper oillevels,
c'. Conclusions
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One unresolved item was identified concerning the determination of proper oil level
for rotating equipment. The inspectors concluded that engineering did not have an
adequate understanding of proper lubrication levels for the plant specific equipment.
E2.2 Oil Analysis for Rotatina Eauipment
a. Inspection Scope (37550)
Emergency Diesel Generator 12 had the outboard alternator bearings replaced in
November 1996. The inspectors reviewed the oil analysis that led up to the
, replacement and following the replacement.
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b, Observations and Findinas
The licensee used oil analysis as a tool to predict future problems with equipment.
A graph of the severe wear indication (SWI) for the outboard alternator bearing
from late 1992 to October 1996 did not show a trend before a significant step
change. Before bearing replacement in November 1996, the graphed data was
scattered with the highest value less then 20,000 and most values less then
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10,000 SWI. Less then 10,000 SWI was the expected value, in November 1996,
the indication reached 110,000 as a step change and the bearing was changed out.
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Following the bearing replacement, the oil analysis for SWI continued to be
' scattered with all but one value above the 10,000 SWI maximum expected value.
The licensee indicated that the higher than-expected values after the bearing
i change were due to break in wear on the bearing; however, the licensee had not
j. contacted the vendor for guidance on how long the break-in period should be.
j During the EDG 12 outage, the bearing oil reservoir was drained and refilled to the
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i top of the sight glass level, and the engine was rotated two revolutions. Then the
j oil was drained and replaced. The oil sample after the 3-hour post-maintenance
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testing resulted in an SWI of 12,480.
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The inspectors further noted that the information provided to an independent
[ laboratory performing a separate oil analysis was not complete. The laboratory was
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not provided with the service timo of the bearing and its oil. Without correlating
the service time of these two factors, the results could be misleading.
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c. Conclusion
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The licensee had been monitoring bearing vibrations for the EDG 12 alternator; the
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data appears satisfactory. However, not knowing the expected break-in period for
, the bearing and not trending the oil analysis with respect to the service time of the
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bearing and oil raised additional uncertainties concerning the status of the bearing,
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The inspectors considered this lack of knowledge a weakness in engineering
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support to maintaining the plant.
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h E2.3 Inadeauate Enaineerina Evaluation of Parts and Components
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a. inspection Scope (37550)
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During the observation of maintenance activities on EDG 12, the inspectors noted
that three parts installed during the maintenance were nonsafety-related. The
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, inspectors discussed the use of nonsafety-related parts on safety-related equipment
- with the licensee and reviewed engineering evaluations for the three nonsafety-
i related parts used on EDG 12.
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b. Observations and Findinas
inadeauate Enaineerina Evaluation for Use of Nonsafetv-Related Parts in EDGs
Plant procedures required an engineering evaluation if nonsafety-related parts were
used for the repair or modification of safety-related equipment. The evaluation
would be performed to verify the acceptability of the part to be used.
Engineering evaluations for two of the nonsafety-related parts installed on EDG 12
on May 13,1997, appeared to be adequate. However, the evaluation for the third
part, a rectangular vegetable fiber gasket used for the turbo charger blower cover
gasket, appeared to be inadequate. The engineering evaluation checklist for the
evaluation, dated August 2,1989, indicated that the gasket did not perform a
critical function and would not fail. However, the inspectors disagreed with this
conclusion. The possibility of causing significant operational problems appeared to
exist if the gasket failed. In addition, five questions were inappropriately marked
"NA" and the required justifications were not included for answers to the questions
on the form.
10 CFR 50, Appendix B, Criterion Ill, " Design Control," required that measures be
established for the selection and review for sui *sbility of application of materials,
parts, equipment and processes that are essential to the safety-related functions of i
structures, systems and components. The installation of the nonsafety-related I
turbo charger blower cover gasket on safety-related EDG 12 without performing an I
adequate engineering evaluation which addressed the suitability of application of
the parte to the safety-related functions of the EDGs is an example of a violation of
10 CFR 50, Appendix B, Criterion 111 (VIO 50-341/97005-04a).
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The inspectors identified this problem to the licensee personnel and management
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during several discussions. During the discussions of this problem, licensee
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personnel stated that DER 96-0903 had been written on inadequate justifications l
for engineering evaluations on August 7,1996. The action taken on the DER
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appeared to be limited to enhancement of the evaluation criteria and did not
address reevaluation or control of parts which were previously inadequately l
evaluated. The inspectors noted that the DER stated, "This is a weakness, not a
serious problem."
The action taken on DER 96-0903 to correct the problem of weak evaluations for
using nonsafety-related parts in safety-related applications was inadequate. In
addition the previously identified deficient evaluation for the gasket was not
corrected. As a result, the licensee continued to install similar gaskets in EDG 13
on May 20 and in EDG 14 on May 27, without further evaluations. Until a proper
engineering evaluation is completed, it is not known if these gaskets would affect
the operation of the three EDGs.
Even though DER 96-0903 was written on this problem on August 7,1996, no
actions were taken to verify the adequacy of engineering evaluations prior to use of
nonsafety-related parts and no controls were in place to prevent the installation of
inadequately evaluated nonsafety related parts. As a result, inadequately evaluated
nonsafety-related parts continued to be used in safety-related equipment until at
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least May 27,1997. This is an example of a violation of Criterion 111(50-
341/97005-04B(DRS)).
Generic Justification for Use of Parts in Plant Eauipment
The licensee has assigned a generic plant identification system (PIS) number for
ordering expendable items such as rags, cleaners, etc. Licensee personnel stated
that this PIS number was not intended for parts used in plant equipment. The
licensee identified that plant personnel had inappropriately used this generic PIS
number to order nonsafety-related parts to be installed in the plant. The licensee
indicated that the root cause appeared to be a lack of knowledge of the purpose of
this PIS number. In other cases, personnel appeared to use this PlS number to
avoid required engineering evaluations for nonsafety-related parts. The licensee
stated that additional training was to be provided to maintenance personnel. In
addition, a memorandum was issued by the Plant Manager to clarify the use of
generic PIS numbers and ensure that engineering evaluations would be performed
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when needed. Licensee action on this problem appeared to be adequate.
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c. Conclusions
One violation with two examples was identified concerning poor design control for l
use of nonsafety-related parts in safety-related systems. Material control practices l'
appeared to be weak. Some engineering evaluations, allowing the use of
nonsafety-related parts in safety-related equipment, were inadequate. In addition,
licensee personnel had found ways to bypass the entire process. The emphasis l
appeared to be on expediting work without significant concern about the integrity
of replacement parts. l
In using nonsafety-related gaskets on EDGs, the licensee appeared to be slow in
responding to the concern and providing addit.:onal evaluations.
E8 Miscellaneous Engineering issues
E8.1 LClosed) Violation 50-341/95003-03: Use of unapproved material on safety-related
equipment. This violation was written for using non-approved cleaners and
lubricants in electrical applications. The inspectors reviewed procedure
35.000.217, " Maintenance Lubrication," Revision 28, and other actions taken to
ensure that only approved lubricants and cleaners were used to clean and lubricate
safety related components. Actions taken included a prohibition on the use of
Cramolin, a known non qualified contact cleaner. During the observation of
maintenance activities the inspectors noted thet only approved cleaners and
lubricants were used. This item is closed.
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V. Manaaement Meetinas
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on May 30,1997. The licensee acknowledged the findings
presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
S. Booker, General Supervisor, Electrical Maintenance
l P. Borer, Vice President
l D. Cobb, Superintendent, Operations
R. Cook, Acting Supervisor, Compliance
M. Caragher, Supervisor, Material Engineering
R. Delong, Superintendent, System Engineering ,
P. Fessler, Plant Manager, Operations i
D. Gipson, Senior Vice President, Generation
! J. Green, Maintenance Superintendent, Maintenance Support )
l J. Hughes, Supervisor, inspection and Surveillance, QC 1
j' R. Matthews, Maintenance Superintendent l&C '
N. Peterson, Acting Director, Licensing
K. Sessions, Work Control
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- T. Schehr, Engineer, Operations
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R. Wittschen, Compliance Engineer
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G. Harris, Senior Resident inspector ,
N. O'Keefe, Resident inspector
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INSPECTION PROCEDURES USED
IP 37550: Engineering
IP 62703: Maintenance Observatim
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
50-341/97005-01 VIO failure to maintain DFP engine speed within acceptable
operating limits and to perform adequate PMT
50-341/97005-02 VIO failure to have approved instructions prior to performing
maintenance on a spare disconnect switch
G0 341/97005-03 URI licensee review of lubricating levels for rotating equipment
50-341/97005-04 VIO inadequate engineering evaluation of nonsafety-related parts
Closed
50-341/95003-03 VIO use of unapproved material on equipment
50-341/95012-02b VIO deterioration of station batteries
50-341/95012-04a VIO inadequate procedure rendered a station battery in inoperable
50-341/95012-04b VIO inadequate procedure placed a station battery in service before
maintenance was completed
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50-341/96013-03 VIO failure to identify and correct a disconnected electrical lead
Discussed
50-341/95012-O'2a VIO use of inadequate procedures in performing electrical
maintenance activitics
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LIST OF ACRONYMS USED
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CFR Code of Federal Regulations
CCHVAC Control Room Heating l Ventilation and Air Conditioning
DECO Detroit Edison Company
DER Deviation Event Report
DFP Diesel Fire Pump
DRS Division of Reactor Safety
EDG Emergency Diesel Generator
FME Foreign Material Exclusion
HPCI High Pressure Coolant injection '
l l&C Instrumentation and Control
M&TE Measurement and Test Equipment l
MCC Motor Control Center
MMA Maintenance Conduct Manual
NRC Nuclear Regulatory Commission
i NSS Nuclear Shift Supervisor
l NUREG Nuclear Regulatory Guide
PDR Public Document Room 1
PMT Post-Maintenance Testing
l QA Quality Assurance
SWI Severe Wear Indication 1
TIR Total Indicated Runout b
TS Technical Specification I
TWMS Torus Water Management System
URI Unresolved item
VIO Violation
W RIF Work Request initiation Form
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