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                            U. 5. NUCLEAR REGULATORY COMMISSION
U. 5. NUCLEAR REGULATORY COMMISSION
                                        REGION III
REGION III
    Report No. 50-341/85029(DRP)
Report No. 50-341/85029(DRP)
    Docket No. 50-341                                   Operating License No. NPF-33
Docket No. 50-341
    Licensee: Detroit Edison Company
Operating License No. NPF-33
                2000 Second Avenue
Licensee: Detroit Edison Company
                Detroit, MI 48226
2000 Second Avenue
    Facility Name: Fermi 2
Detroit, MI 48226
    Inspection At: Fermi Site, Newport, MI
Facility Name: Fermi 2
    Inspection Conducted: June 1-30, 1985
Inspection At: Fermi Site, Newport, MI
    Inspectors:     P. M. Byron
Inspection Conducted: June 1-30, 1985
                    M. E. Parker
Inspectors:
                    D. C. Jones
P. M. Byron
                    R. A. Paul
M. E. Parker
                      Q L O /1A''
D. C. Jones
    Approved by:   G. C. Wright, Chief                                   -) /d b!
R. A. Paul
                    Projects Section 2C                                 Date
Q L O /1A''
    Inspection Summary
Approved by:
    Inspection on June 1-30, 1985, (Report No. 50-341/85029(DRP))
G. C. Wright, Chief
    Areas Inspected: Routine, unannounced inspection by resident inspectors of
-) /d b!
    licensee action on previous inspector identified items; independent inspection;
Projects Section 2C
    maintenance; surveillance; operational safety - ESF system walkdown; fire
Date
    prevention / protection program implementation; allegations, management meetings,
Inspection Summary
    SALP, and initial criticality. The inspection involved a total of 323
Inspection on June 1-30, 1985, (Report No. 50-341/85029(DRP))
    inspector-hours onsite by four NRC inspectors, including 82 inspector-hours
Areas Inspected: Routine, unannounced inspection by resident inspectors of
    onsite during off-shifts.
licensee action on previous inspector identified items; independent inspection;
    Results: Five open items, three license condition attachments (one of which
maintenance; surveillance; operational safety - ESF system walkdown; fire
    was also an open item), and one noncompliance were closed. Two unresolved and
prevention / protection program implementation; allegations, management meetings,
    one open item resulted from this inspection. Within the areas inspected, no
SALP, and initial criticality. The inspection involved a total of 323
    violations, deviations, or significant safety issues were identified.
inspector-hours onsite by four NRC inspectors, including 82 inspector-hours
    8500020003 850729
onsite during off-shifts.
    PDR   ADOCK 05000341
Results: Five open items, three license condition attachments (one of which
    0                   PM
was also an open item), and one noncompliance were closed. Two unresolved and
,                 -                                                           ,
one open item resulted from this inspection. Within the areas inspected, no
violations, deviations, or significant safety issues were identified.
8500020003 850729
PDR
ADOCK 05000341
0
PM
,
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                                                DETAILS
DETAILS
9
9
      1.   Persons Contacted
1.
            *F. Agosti, Manager, Nuclear Operations
Persons Contacted
            *L. Bregni, Licensing Engineer
*F. Agosti, Manager, Nuclear Operations
              J. DuBay, Director, Planning and Control
*L.
              0. Earle, Supervisor, Licensing
Bregni, Licensing Engineer
              R. Eberhardt, Rad-Chem Engineer
J. DuBay, Director, Planning and Control
              P. Fessler, Assistant Maintenance Engineer
0. Earle, Supervisor, Licensing
            *E. Griffing, Assistant Manager, Nuclear Operations                           i
R. Eberhardt, Rad-Chem Engineer
P. Fessler, Assistant Maintenance Engineer
i
*E. Griffing, Assistant Manager, Nuclear Operations
W.'Jens, Vice-President, Nuclear Operations
4
4
              W.'Jens, Vice-President, Nuclear Operations
W. Kaczor, Director, SAFETEAM (DECO)
              W. Kaczor, Director, SAFETEAM (DECO)
R. Kunkle, Director, SAFETEAM (UTS)
              R. Kunkle, Director, SAFETEAM (UTS)
S. Leach, Director, Nuclear Security
              S. Leach, Director, Nuclear Security
J. Leman, Maintenance Engineer
              J. Leman, Maintenance Engineer
,
,           -L. Lessor, Advisor to the Superintendent, Nuclear Production
-L. Lessor, Advisor to the Superintendent, Nuclear Production
,          *R. Lenart, Superintendent, Nuclear Production
*R. Lenart, Superintendent, Nuclear Production
              R. Mays, Director, Project Planning
,
            *W. Miller, QA Supervisor, Operational     Assurance
R. Mays, Director, Project Planning
              S. Noetzel, Site Manager
*W. Miller, QA Supervisor, Operational Assurance
              J. Nyquist, Assistant to Superintendent, Nuclear Production
S. Noetzel, Site Manager
              G. Overbeck, Assistant Plant Superintendent
J. Nyquist, Assistant to Superintendent, Nuclear Production
              J. Plona, Technical Engineer
G. Overbeck, Assistant Plant Superintendent
J. Plona, Technical Engineer
E. Preston, Operations Engineer
W. Ripley, Startup Director
'
'
              E. Preston, Operations Engineer
C. P. Sexauer, Nuclear Production Administrator
              W. Ripley, Startup Director
i
              C. P. Sexauer, Nuclear Production Administrator
G. Trahey, Director, Nuclear QA
i           G. Trahey, Director, Nuclear QA
l
l           * Denotes those who attended the exit meetings.
* Denotes those who attended the exit meetings.
I
I
The-inspectors also interviewed others of the licensee's staff during
!
!
            The-inspectors also interviewed others of the licensee's staff during        -
-
            this inspection.
this inspection.
      2.   Followup on Inspector Identified Items
2.
            a.       -(Closed) Open Item (341/84003-06(DRSS)), and License Condition
Followup on Inspector Identified Items
                    Attachment 1, B.2.b:   Fabricate and install an intrinsic germanium
a.
                    detector system post-accident collimator prior to exceeding ~five     l
-(Closed) Open Item (341/84003-06(DRSS)), and License Condition
                    percent power. The licensee fabricated several lead shield
Attachment 1, B.2.b:
Fabricate and install an intrinsic germanium
detector system post-accident collimator prior to exceeding ~five
l
percent power. The licensee fabricated several lead shield
collimators for accident condition use with the detector system,
'
'
                    collimators for accident condition use with the detector system,
and a calibration was performed for use with a multi-channel
                      and a calibration was performed for use with a multi-channel
'
'
                      analyzer. The licensee demonstrated the use of the collimators       i
analyzer. The licensee demonstrated the use of the collimators
                      for the inspectors. ,The inspectors also reviewed selected sections I
for the inspectors. ,The inspectors also reviewed selected sections
                    of Radiological Engineering Report.No. 85-02, " Calibration of High-
of Radiological Engineering Report.No. 85-02, " Calibration of High-
                    Purity-Germanium Detector-for Use with~ Lead Collimators to Analyze
Purity-Germanium Detector-for Use with~ Lead Collimators to Analyze
                  .High activity Post-Accident Samples."
.High activity Post-Accident Samples."
,
,
                                                    2'
2'
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        .-                       -                       - --
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      - b. (Closed) Open Item (341/84039-01(DRP)), and License Condition
--
          Attachment 1, B.1.a: Accessibility of safety-related valves for
.
          serviceability and manual operation. This item identified numerous
.
          inaccessible safety-related valves that would require ladders or
- b.
          platforms to operate, inspect, and maintain the valves.
(Closed) Open Item (341/84039-01(DRP)), and License Condition
          (1) Concerning the manual operation of safety-related valves, the
Attachment 1, B.1.a:
                licensee conducted a program that reviewed 217 safety-related
Accessibility of safety-related valves for
                valves for accessibility. Of the 217 valves, 69 or 32 percent
serviceability and manual operation. This item identified numerous
                required some form of accessibility aid       The results of this
inaccessible safety-related valves that would require ladders or
                accessibility program are as follows
platforms to operate, inspect, and maintain the valves.
                *
(1) Concerning the manual operation of safety-related valves, the
                      Temporary scaffolding and lar.ders have been installed in
licensee conducted a program that reviewed 217 safety-related
                      several cases which will proside an interim resolution
valves for accessibility. Of the 217 valves, 69 or 32 percent
                      until permanent design chang ss can be implemented.
required some form of accessibility aid
                *
The results of this
                      Portable stands, air hoists, and rolling platforms have
accessibility program are as follows
                      been chained and locked in strategic locations for the
*
                      other cases, which will provide a more permanent accessi-
Temporary scaffolding and lar.ders have been installed in
                      bility. All operators have a key to the locks and have
several cases which will proside an interim resolution
                      been briefed on the operation and the locations of these
until permanent design chang ss can be implemented.
                      devices.
*
Portable stands, air hoists, and rolling platforms have
been chained and locked in strategic locations for the
other cases, which will provide a more permanent accessi-
bility. All operators have a key to the locks and have
been briefed on the operation and the locations of these
devices.
(2) Although the accessibility of safety-related valves for
#
#
          (2) Although the accessibility of safety-related valves for
operation was the primary issue of concern, the licensee
                operation was the primary issue of concern, the licensee
has developed a program which will address the issue of
                has developed a program which will address the issue of
serviceability. The program will consider the same 217
                serviceability. The program will consider the same 217
safety-related valves as the operability program, but from
                safety-related valves as the operability program, but from
a maintenance perspective. This will be accomplished through
                a maintenance perspective. This will be accomplished through
the Engineering Evaluation Request (EER) process which shall
                the Engineering Evaluation Request (EER) process which shall
provide an evaluation and design for the permanent installation
                provide an evaluation and design for the permanent installation
of serviceability aids. This item requires further review and
                of serviceability aids. This item requires further review and
evaluation and is considered an unresolved item (341/85029-
                evaluation and is considered an unresolved item (341/85029-
01(DRP)) pending completion of the serviceability program and
                01(DRP)) pending completion of the serviceability program and
_
                          _
subsequent NRC inspection.
                subsequent NRC inspection.
The licensee has demonstrated adequate accessibility to all con-
          The licensee has demonstrated adequate accessibility to all con-
cerned safety-related valves. This satisfies the license condition
          cerned safety-related valves. This satisfies the license condition
for criticality and this item is considered closed.
          for criticality and this item is considered closed.
c.
      c. (Closed) Open Item (341/84043-05(DRSS)): Complete Installation of
(Closed) Open Item (341/84043-05(DRSS)): Complete Installation of
          Standby Gas Treatment System (SGTS) sample line heat tracing prior
Standby Gas Treatment System (SGTS) sample line heat tracing prior
          to exceeding five percent power. The heat tracing has been
to exceeding five percent power. The heat tracing has been
          installed, and the functional tests have been completed and
installed, and the functional tests have been completed and
          reviewed. The inspectors verified the installation of the heat
reviewed. The inspectors verified the installation of the heat
          tracing.
tracing.
                                          3.
3.
                                                                                  -
_
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.
.
    d.   (Closed) Open Item (341/84043-10(DRSS)), and License Condition
.
          Attachment 1, B.2.c:   Complete a comprehensive review of technical
d.
          adequacy, commitment compliance, necessary corrective actions and
(Closed) Open Item (341/84043-10(DRSS)), and License Condition
          associated training for the accident radioactive effluent release
Attachment 1, B.2.c:
          quantification program prior to exceeding five percent power. The
Complete a comprehensive review of technical
          licensee has completed the comprehensive review of technical adequacy
adequacy, commitment compliance, necessary corrective actions and
          and commitment compliance and taken corrective action by revising
associated training for the accident radioactive effluent release
          certain emergency response and plant procedures. These actions are
quantification program prior to exceeding five percent power. The
          described in a licensee internal document entitled " Accident Radio-
licensee has completed the comprehensive review of technical adequacy
          active Release Quantification Program," which the inspectors reviewed.
and commitment compliance and taken corrective action by revising
          Also completed are the approval of revised procedures and the training
certain emergency response and plant procedures. These actions are
          of personnel on these revised procedures.
described in a licensee internal document entitled " Accident Radio-
    e.   (Closed) Open Item (341/85010-02(DRP)): Verification of the proper
active Release Quantification Program," which the inspectors reviewed.
          operation of 24 single coil Target Rock solenoid valves. The 24
Also completed are the approval of revised procedures and the training
          single coil Target Rock valves consist of 16 valves in the Post
of personnel on these revised procedures.
          Accident Sampling System, and 8 valves in the MSIV Leakage Control
e.
          System. Preoperational Test Procedure PRET.P3323.001, " Post
(Closed) Open Item (341/85010-02(DRP)): Verification of the proper
          Accident Sampling System," included proper operation verification
operation of 24 single coil Target Rock solenoid valves. The 24
          for 14 of the valves. Plant Operations Manual (POM) Surveillance
single coil Target Rock valves consist of 16 valves in the Post
          Procedure 24.127.20, "MSIV Leakage Control System Local Valve
Accident Sampling System, and 8 valves in the MSIV Leakage Control
          Position Indication Verification Test," included proper operation
System. Preoperational Test Procedure PRET.P3323.001, " Post
          verification for eight of the valves. POM Surveillance Procedure
Accident Sampling System," included proper operation verification
          43.401.383, " Local Leakage Rate Testing For Penetration X-215,"
for 14 of the valves. Plant Operations Manual (POM) Surveillance
          included proper operation verification for two of the valves. All
Procedure 24.127.20, "MSIV Leakage Control System Local Valve
          single coil Target Rock solenoid valves operated properly. This
Position Indication Verification Test," included proper operation
          item is considered closed.
verification for eight of the valves. POM Surveillance Procedure
    f.   (Closed) Noncompliance (341/85021-01(DRP)): Inadequate implementa-
43.401.383, " Local Leakage Rate Testing For Penetration X-215,"
    tion and review of Engineering Design Package EDP-1996 and the accompany-
included proper operation verification for two of the valves. All
    ing Engineering Change Requests (ECR's) used to verify installation of
single coil Target Rock solenoid valves operated properly. This
    test, vent, and drain connection caps. This resulted in:     (a) the EDP
item is considered closed.
    verification sheet not adequately reflecting the EDP and its accompanying
f.
    ECR's, (b) not all test, vent, and drain (TVD) caps being installed, and
(Closed) Noncompliance (341/85021-01(DRP)):
    (c) Plant Operations Manual (POM) Procedure 47.000.77, " Test, Vent, and
Inadequate implementa-
    Drain (TVD) Cap and Plug Verification," omitting a penetration (X-220)
tion and review of Engineering Design Package EDP-1996 and the accompany-
    which consists of eight TVD caps. The following licensee corrective
ing Engineering Change Requests (ECR's) used to verify installation of
    action was implemented:
test, vent, and drain connection caps. This resulted in:
          (1) The EDP verification sheet was corrected to incorporate all
(a) the EDP
              revisions to EDP-1996 and the walkdown was reperformed. Also,
verification sheet not adequately reflecting the EDP and its accompanying
              the EDP Implementation Plan was revised as required by POM
ECR's, (b) not all test, vent, and drain (TVD) caps being installed, and
              Procedure 12.000.64, "EDP Implementation." The individual who
(c) Plant Operations Manual (POM) Procedure 47.000.77, " Test, Vent, and
                incorrectly implemented this procedure was instructed to read
Drain (TVD) Cap and Plug Verification," omitting a penetration (X-220)
              the procedure again and fully acquaint himself with all of its   i
which consists of eight TVD caps. The following licensee corrective
                requirements,
action was implemented:
                                                                                i
(1) The EDP verification sheet was corrected to incorporate all
                                                                                !
revisions to EDP-1996 and the walkdown was reperformed. Also,
                                                                                !
the EDP Implementation Plan was revised as required by POM
                                                                                i
Procedure 12.000.64, "EDP Implementation." The individual who
                                                                                1
incorrectly implemented this procedure was instructed to read
                                                                                i
the procedure again and fully acquaint himself with all of its
                                        4
i
requirements,
i
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.
.
      (2) Completion of PN-21 No. 992725 and the revised verification
.
            walkdown documents that all caps are now installed in accordance
(2) Completion of PN-21 No. 992725 and the revised verification
            with EDP 1996 and ECP's 1996-1 and 1996-2. Surveillance Pro-
walkdown documents that all caps are now installed in accordance
            cedure 47.000.77 has been issued to administrative 1y control
with EDP 1996 and ECP's 1996-1 and 1996-2.
            the subject caps. Also, all associated plant drawings will be
Surveillance Pro-
            updated in accordance with proper procedure to reflect as-built
cedure 47.000.77 has been issued to administrative 1y control
            conditions.
the subject caps. Also, all associated plant drawings will be
      (3) The preparer and the technical reviewer reanalyzed all informa-
updated in accordance with proper procedure to reflect as-built
            tion used to generate Procedure 47.000.77 and corrected the
conditions.
            procedural _ deficiency. They were then instructed by their
(3) The preparer and the technical reviewer reanalyzed all informa-
            immediate supervisors of the importance of checking and
tion used to generate Procedure 47.000.77 and corrected the
            auditing large amounts of technical data systematically and
procedural _ deficiency. They were then instructed by their
            logically to preclude recurrence of this type of error. The
immediate supervisors of the importance of checking and
            licensee has guidelines to follow in writing procedures which
auditing large amounts of technical data systematically and
            are used to ensure correct technical and work content. The
logically to preclude recurrence of this type of error. The
            individual was also instructed to acquaint himself with all
licensee has guidelines to follow in writing procedures which
            the requirements of this procedure.
are used to ensure correct technical and work content. The
      The plant drawings shall be updated to reflect the as-built condition
individual was also instructed to acquaint himself with all
      of the TVD connection caps by November 30,1985. This item is con-
the requirements of this procedure.
      sidered closed.
The plant drawings shall be updated to reflect the as-built condition
    g. (Closed) License Condition 2.c.(12): Operability of the permanent
of the TVD connection caps by November 30,1985. This item is con-
      liquid radwaste treatment system prior to exceeding five percent
sidered closed.
      power. The licensee has completed the preoperational tests and
g.
      demonstrated that the system is operable. The system has been
(Closed) License Condition 2.c.(12): Operability of the permanent
      turned over to operations. Several test exceptions which do not
liquid radwaste treatment system prior to exceeding five percent
      affect the operability of the system remain open. A selected review
power. The licensee has completed the preoperational tests and
      of preoperational test results (G1120.001 and G1125.001) was made by
demonstrated that the system is operable. The system has been
      the inspectors. In addition the inspectors walked down several
turned over to operations. Several test exceptions which do not
      sections of the liquid radwaste system.
affect the operability of the system remain open. A selected review
    h. (Closed) License Condition 2.c.(16): Operability of the Post-
of preoperational test results (G1120.001 and G1125.001) was made by
      Accident Sampling System (PASS), THI Action Item II.B.3. The
the inspectors.
      SER, Supplement No. 5 dated March 1985, states that the applicant
In addition the inspectors walked down several
      must demonstrate the capability of promptly obtaining a reactor
sections of the liquid radwaste system.
      water coolant sample in the case of an accident, and that the PASS
h.
      meets all the requirements of Task Action Item II.B.3 and is
(Closed) License Condition 2.c.(16): Operability of the Post-
      therefore acceptable. Since the SER was written, the licensee has:
Accident Sampling System (PASS), THI Action Item II.B.3.
      demonstrated the PASS operable; approved POM procedure 78.000.14
The
      which provides detailed instructions for the collection and analysis
SER, Supplement No. 5 dated March 1985, states that the applicant
      of samples obtained by the PASS; provided training in the required
must demonstrate the capability of promptly obtaining a reactor
      procedures; and performed a time and motion study to demonstrate
water coolant sample in the case of an accident, and that the PASS
      that PASS samples can be collected, transported, and analyzed in
meets all the requirements of Task Action Item II.B.3 and is
      accordance with NUREG 0737, Regulatory Guide 1.97, and GDC-19 dose
therefore acceptable. Since the SER was written, the licensee has:
      criteria. Selected review of the procedures, training records, and
demonstrated the PASS operable; approved POM procedure 78.000.14
      the time and motion study was made by the inspectors.
which provides detailed instructions for the collection and analysis
                                        5
of samples obtained by the PASS; provided training in the required
                                                                              j
procedures; and performed a time and motion study to demonstrate
that PASS samples can be collected, transported, and analyzed in
accordance with NUREG 0737, Regulatory Guide 1.97, and GDC-19 dose
criteria. Selected review of the procedures, training records, and
the time and motion study was made by the inspectors.
5
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                                                                              .
.
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    3. Independent Inspection
3.
        a.   Temporary Solid Radwaste System
Independent Inspection
            The licensee intends to use a portable solid radwaste treatment
a.
            system (NUS) to meet their technical specification requirements
Temporary Solid Radwaste System
            until the completion of the preoperational tests and final approval
The licensee intends to use a portable solid radwaste treatment
            of the permanent solidification system. The system, which is
system (NUS) to meet their technical specification requirements
l           located in the radwaste building, is operable and will be used by
until the completion of the preoperational tests and final approval
            NUS contractor personnel in accordance with approved licensee
of the permanent solidification system. The system, which is
            procedures. The licensee tested the portable system by solidifying
l
            88 cubic feet of mixed bed bead resin from floor drain and waste
located in the radwaste building, is operable and will be used by
            collector tanks to verify the system met the licensee acceptance
NUS contractor personnel in accordance with approved licensee
            criteria. Selected results of these tests were reviewed by the
procedures. The licensee tested the portable system by solidifying
            inspectors; no problems were noted. The inspectors also: discussed
88 cubic feet of mixed bed bead resin from floor drain and waste
            the results of a licensee conducted ALARA review of the temporary
collector tanks to verify the system met the licensee acceptance
            system with radwaste personnel; walked down the system to verify
criteria. Selected results of these tests were reviewed by the
            installation; and observed selected components to identify potential
inspectors; no problems were noted. The inspectors also: discussed
            radiological problem areas. No significant problems were identified.
the results of a licensee conducted ALARA review of the temporary
            In a letter to the licensee from the NRC dated July 3, 1985, NRR
system with radwaste personnel; walked down the system to verify
            approved the licensee Process Control Program (PCP) for the
installation; and observed selected components to identify potential
            temporary radwaste system. Based on the acceptance of the PCP, the
radiological problem areas. No significant problems were identified.
            demonstration test of the system, and the inspector's review of the
In a letter to the licensee from the NRC dated July 3, 1985, NRR
            system, it appears the portable system will function as described in
approved the licensee Process Control Program (PCP) for the
            the vendor's topical report (NUS Topical Report PS-53-00378) which
temporary radwaste system. Based on the acceptance of the PCP, the
            was submitted to the NRC by the licensee.
demonstration test of the system, and the inspector's review of the
            No violations or deviations were identified in the review of this
system, it appears the portable system will function as described in
            program area.
the vendor's topical report (NUS Topical Report PS-53-00378) which
        b.   Onsite Storage Facility (OSSF)
was submitted to the NRC by the licensee.
            The licensee's onsite storage facility is described in Section 11B.1
No violations or deviations were identified in the review of this
            of the FSAR. The facility is intended to provide interim storage
program area.
            capacity for an amotint of waste which could be generated in five
b.
            years of plant operation. -During this inspection, and a previous
Onsite Storage Facility (OSSF)
            inspection (Report No. 50-341/85017(DRSS)), tours and discussions
The licensee's onsite storage facility is described in Section 11B.1
            concerning the OSSF were made. The tours were made to verify that
of the FSAR. The facility is intended to provide interim storage
            selected systems and components (including area radiation and
capacity for an amotint of waste which could be generated in five
            effluent monitors) were installed in accordance with the FSAR and to
years of plant operation. -During this inspection, and a previous
            identify any potential radiological problem areas. No problems were
inspection (Report No. 50-341/85017(DRSS)), tours and discussions
            noted.
concerning the OSSF were made. The tours were made to verify that
            During these tours and discussions with the licensee, special atten-
selected systems and components (including area radiation and
            tion was given to the handling, decontamination, smearing, and
effluent monitors) were installed in accordance with the FSAR and to
            surveying of dry active and solidified waste drums; to the HVAC
identify any potential radiological problem areas. No problems were
                                                                          ,
noted.
                                            6
During these tours and discussions with the licensee, special atten-
tion was given to the handling, decontamination, smearing, and
surveying of dry active and solidified waste drums; to the HVAC
,
6
4
4
                                *                                       e
*
e


  i
i
      .
.
    .
.
          system; to the design features to ensure ALARA; and to the portable
system; to the design features to ensure ALARA; and to the portable
          solid radwaste system located in the truck bay area of the OSSF.
solid radwaste system located in the truck bay area of the OSSF.
          Radiation protection features of the OSSF include: protective
Radiation protection features of the OSSF include: protective
          barriers around the stored waste to prevent uncontrolled releases to
barriers around the stored waste to prevent uncontrolled releases to
          the environment, remote handling of the waste drums, routing of all
the environment, remote handling of the waste drums, routing of all
          potentially contaminated drains from the OSSF to plant liquid
potentially contaminated drains from the OSSF to plant liquid
          radwaste system (the licensee verified each floor drain from the
radwaste system (the licensee verified each floor drain from the
          OSSF is routed to the liquid radwaste system), and monitoring and
OSSF is routed to the liquid radwaste system), and monitoring and
          filtration of gaseous and particulate effluents.
filtration of gaseous and particulate effluents.
          One ALARA problem was noted in that no shielding had been provided
One ALARA problem was noted in that no shielding had been provided
          in the radwaste barrel readout area, nor had provisions been made to
in the radwaste barrel readout area, nor had provisions been made to
          read out the barrels remotely. The licensee stated they would
read out the barrels remotely. The licensee stated they would
          review the read out system and make improvements where feasible.
review the read out system and make improvements where feasible.
          This program area requires further review and evaluation and is
This program area requires further review and evaluation and is
          considered an open item (50-341/85029-02(DRP))
considered an open item (50-341/85029-02(DRP))
          No violations or deviations were identified in the review of this
No violations or deviations were identified in the review of this
          program area.
program area.
        c. SAFETEAM
c.
          The Office of Investigation (OI) reviewed the investigative results
SAFETEAM
          of SAFETEAM concerns based on issues raised during the licensing
The Office of Investigation (OI) reviewed the investigative results
          process of another utility. June 11-13, 1985, OI investigators
of SAFETEAM concerns based on issues raised during the licensing
          reviewed the SAFETEAM investigators' packages for those concerns
process of another utility. June 11-13, 1985, OI investigators
          which had been identified as wrongdoing. The wrongdoing concerns
reviewed the SAFETEAM investigators' packages for those concerns
          had been forwarded to Region III as they had been identified. OI
which had been identified as wrongdoing. The wrongdoing concerns
          investigators expanded the scope of their review when they returned
had been forwarded to Region III as they had been identified. OI
          June 18-20, 1985, to include the completed investigative packages of
investigators expanded the scope of their review when they returned
          those concerns which the investigators deemed as potential wrongdoing
June 18-20, 1985, to include the completed investigative packages of
          based on the description listed in the SAFETEAM computor printout.
those concerns which the investigators deemed as potential wrongdoing
          The review included listening to the tapes, reading the transcription,
based on the description listed in the SAFETEAM computor printout.
          and reviewing the documentation in the packages.
The review included listening to the tapes, reading the transcription,
          The Director of OI, members of his staff, and NRR attended a
and reviewing the documentation in the packages.
          briefing at the site on June 19, 1985, by the licensee and the OI
The Director of OI, members of his staff, and NRR attended a
          investigators.
briefing at the site on June 19, 1985, by the licensee and the OI
                                                                                  1
investigators.
          As a result of the OI concerns, a task force composed of individuals
1
          from NRR, I&E, and Region III were at the site June 27 and 28, 1985,
As a result of the OI concerns, a task force composed of individuals
          to perform a more detailed investigation of SAFETEAM concerns for
from NRR, I&E, and Region III were at the site June 27 and 28, 1985,
          technical merit and a comparison of the SAFETEAM off ort with that of
to perform a more detailed investigation of SAFETEAM concerns for
          a similar undertaking by another utility.
technical merit and a comparison of the SAFETEAM off ort with that of
          The inspectors supported the OI and task force efforts.
a similar undertaking by another utility.
          In conjunction with this effort, the inspectors and the licensee
The inspectors supported the OI and task force efforts.
          performed an inspection of the safety-related SAFETEAM findings at
In conjunction with this effort, the inspectors and the licensee
          the request of Region III. The inspectors reviewed the SAFETEAM
performed an inspection of the safety-related SAFETEAM findings at
          findings to determine if investigative effort adequately addressed
the request of Region III. The inspectors reviewed the SAFETEAM
          the concern and if the corrective action had been completed.
findings to determine if investigative effort adequately addressed
the concern and if the corrective action had been completed.
i
i
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7
!
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f


                                                                        .
.
    .
.
  .
.
            Also, the licensee performed an independent inspection of the
Also, the licensee performed an independent inspection of the
            SAFETEAM findings to verify adequacy of investigation and corrective
SAFETEAM findings to verify adequacy of investigation and corrective
            acti'on. Through discussions with the licensee, the licensee agreed
acti'on. Through discussions with the licensee, the licensee agreed
            to review fifty percent of the hardware and software safety-related
to review fifty percent of the hardware and software safety-related
            concerns. The inspectors reviewed a sampling of the remaining fifty
concerns. The inspectors reviewed a sampling of the remaining fifty
            percent of the safety-related concerns. The results of these
percent of the safety-related concerns. The results of these
            inspections will be documented in Inspection Report 50-341/85037.
inspections will be documented in Inspection Report 50-341/85037.
            No violations or deviations were identified in the review of this
No violations or deviations were identified in the review of this
            program area.
program area.
      d.   Operational Readiness
d.
            The licensee continues to make progress in its preparations for
Operational Readiness
            power ascension. Fire detector installation, fire door inspection,
The licensee continues to make progress in its preparations for
            and the off gas system appear to be the most significant critical
power ascension. Fire detector installation, fire door inspection,
            path items.
and the off gas system appear to be the most significant critical
            Senior Region III management met with licensee management twice
path items.
            during the inspection period to review the status of items affecting
Senior Region III management met with licensee management twice
            initial criticality and power ascension, license conditions and
during the inspection period to review the status of items affecting
            other areas of mutual interest.
initial criticality and power ascension, license conditions and
            No violations or deviations were identified in the review of this
other areas of mutual interest.
            program area.
No violations or deviations were identified in the review of this
      e.   Independent Operational Readiness Assessment Inspection
program area.
            A Region III team composed of experienced resident inspectors per-
e.
            formed an operational readiness inspection at Fermi 2 during
Independent Operational Readiness Assessment Inspection
            June 17-22, 1985. The purpose of the team inspection was to observe
A Region III team composed of experienced resident inspectors per-
            the licensee's operations and review proceduras to identify strengths
formed an operational readiness inspection at Fermi 2 during
            and weaknesses. The team concluded that there were no significant
June 17-22, 1985. The purpose of the team inspection was to observe
            weaknesses observed and the plant was ready for power ascension.
the licensee's operations and review proceduras to identify strengths
            This inspection is documented in Inspection Report 50-341/85031(DRP).
and weaknesses. The team concluded that there were no significant
            No violations or deviations were identified in the review of this
weaknesses observed and the plant was ready for power ascension.
            program area.
This inspection is documented in Inspection Report 50-341/85031(DRP).
    4. Fire Prevention / Protection Program Implementation
No violations or deviations were identified in the review of this
      The inspectors observed the progress of License Condition 9.e. which
program area.
      requires that prior to exceeding five percent power, all early warning
4.
      fire detectors shall be installed and all fire door assemblies shall be
Fire Prevention / Protection Program Implementation
      labeled or listed by a nationally recognized testing laboratory. The
The inspectors observed the progress of License Condition 9.e. which
      inspectors additionally performed a more detailed examination of the
requires that prior to exceeding five percent power, all early warning
      corrective action by the licensee on a sample basis to determine if the       ,
fire detectors shall be installed and all fire door assemblies shall be
      programmatic requirements were being met.                                     i
labeled or listed by a nationally recognized testing laboratory. The
:
inspectors additionally performed a more detailed examination of the
'                                                                                   l
corrective action by the licensee on a sample basis to determine if the
;     No violations or deviations were identified in the review of this program     I
,
                                                                                    )
programmatic requirements were being met.
      area.
i
:'
;
No violations or deviations were identified in the review of this program
)
'
'
                                                                                    !
area.
                                                                                    l
.
.
                                          8
8
                                                                                  _


  .
.
.
  5. Monthly Maintenance Observation
.
    Station maintenance activities of safety-related systems and components
5.
    listed below were observed to ascertain that they were conducted in
Monthly Maintenance Observation
    accordance with approved procedures, regulatory guides, and industry
Station maintenance activities of safety-related systems and components
    codes or standards and in conformance with Technical Specifications.
listed below were observed to ascertain that they were conducted in
    The following items were considered during this review:     the limiting
accordance with approved procedures, regulatory guides, and industry
    conditions for operation were met while components or systems were
codes or standards and in conformance with Technical Specifications.
    removed from service; approvals were obtained prior to initiating the
The following items were considered during this review:
    work; activities were accomplished using approved procedures and were
the limiting
    inspected as applicable; the procedures used were adequate to control
conditions for operation were met while components or systems were
    the activity; quality control records were maintained; activities were
removed from service; approvals were obtained prior to initiating the
    accomplished by qualified personnel; parts and materials used were
work; activities were accomplished using approved procedures and were
    properly certified; radiological controls were implemented; and fire
inspected as applicable; the procedures used were adequate to control
    prevention controls were implemented.
the activity; quality control records were maintained; activities were
    The following maintenance activity was observed:
accomplished by qualified personnel; parts and materials used were
    *
properly certified; radiological controls were implemented; and fire
          Reactor Water Cleanup (RWCU) Recirculation Pump Rotating
prevention controls were implemented.
          Assembly-Removal and Installation
The following maintenance activity was observed:
    Removal of RWCU recirculation pump "A" rotating assembly was performed
*
    to replace seals and the impeller. Plant Operations Manual (POM)
Reactor Water Cleanup (RWCU) Recirculation Pump Rotating
    Maintenance Procedure 35.000.68, Revision 1 dated February 21, 1979,
Assembly-Removal and Installation
    "RWCU Recirculation Pump Rotating Assembly-Removal and Installation,"
Removal of RWCU recirculation pump "A" rotating assembly was performed
    was used to provide detailed instructions for removal, disassembly,
to replace seals and the impeller.
    inspection, assembly, and installation of the RWCU pump. The inspectors
Plant Operations Manual (POM)
    witnessed portions of this maintenance and identified several areas of
Maintenance Procedure 35.000.68, Revision 1 dated February 21, 1979,
    concern.
"RWCU Recirculation Pump Rotating Assembly-Removal and Installation,"
    a.   Sections 7.1.4.1 through 7.1.4.4 of Procedure 35.000.68 describe
was used to provide detailed instructions for removal, disassembly,
          the steps used in draining the bearing housing oil. This was to be
inspection, assembly, and installation of the RWCU pump. The inspectors
          done prior to the removal of the back pull-out section of the pump.
witnessed portions of this maintenance and identified several areas of
          However, this was not done, resulting in the oil draining out onto
concern.
          the floor during transfer to the rolling cart, and oil draining out
a.
          onto the rolling cart which, in turn, tracked the oil as it was
Sections 7.1.4.1 through 7.1.4.4 of Procedure 35.000.68 describe
          rolled to the workshop.
the steps used in draining the bearing housing oil. This was to be
    b.   Sections 7.1.7 and 7.1.8 and Reference 3.10 (POM Procedure
done prior to the removal of the back pull-out section of the pump.
          32,000.06, " Rigging") of Procedure 35.000.68 provide instructions
However, this was not done, resulting in the oil draining out onto
          for the use of. a chain hoist and suitable sling. The hoist and
the floor during transfer to the rolling cart, and oil draining out
          sling are used to support the back pull-out when the casing stud
onto the rolling cart which, in turn, tracked the oil as it was
          nuts are removed and to facilitate simplified removal of the back
rolled to the workshop.
          pull-out section. However, the maintenance personnel transferred
b.
          the back pull-out section to the rolling cart by hand. This
Sections 7.1.7 and 7.1.8 and Reference 3.10 (POM Procedure
          resulted in three men lifting and carrying the heavy and awkward
32,000.06, " Rigging") of Procedure 35.000.68 provide instructions
          pump to the cart with oil draining significantly (see preceding
for the use of. a chain hoist and suitable sling. The hoist and
          paragraph). Also, Procedure 35.000.68 requires that reference 3.10,
sling are used to support the back pull-out when the casing stud
          POM Procedure 32.000.06 " Rigging," is to be "used". Section 3.0,
nuts are removed and to facilitate simplified removal of the back
          " Rigging Preplanning," of this procedure states "... determine the
pull-out section. However, the maintenance personnel transferred
          weight of the load." The inspectors observed that the licensee did
the back pull-out section to the rolling cart by hand. This
          not observe this requirement of the procedure.
resulted in three men lifting and carrying the heavy and awkward
                                          9
pump to the cart with oil draining significantly (see preceding
paragraph). Also, Procedure 35.000.68 requires that reference 3.10,
POM Procedure 32.000.06 " Rigging," is to be "used".
Section 3.0,
" Rigging Preplanning," of this procedure states "... determine the
weight of the load." The inspectors observed that the licensee did
not observe this requirement of the procedure.
9


                                                                            _.
_.
      .
.
  .
.
                                                                                  l
c.
        c.   The note on page 3 of Procedure 35.000.68 states, " Procedure steps
The note on page 3 of Procedure 35.000.68 states, " Procedure steps
            may be performed out of sequence with the prior approval of the
may be performed out of sequence with the prior approval of the
            DECO Maintenance Foreman (as a minimum). This statement is
DECO Maintenance Foreman (as a minimum). This statement is
applicable until fuel load." However, section 7.5.11 which states. .
,
,
              applicable until fuel load." However, section 7.5.11 which states. .
"to refill the bearing house with Shell Vitrea Oil," was performed
              "to refill the bearing house with Shell Vitrea Oil," was performed
af ter Sections 7.5.12 and 7.5.13.
              af ter Sections 7.5.12 and 7.5.13.   Therefore, the procedure was
Therefore, the procedure was
            performed out of sequence which is a failure to adhere to procedural
performed out of sequence which is a failure to adhere to procedural
              requirements.
requirements.
        d.   There is no procedural step requiring the removal of the casing
d.
            studs. Removal of the back pull-out section is obstructed by the
There is no procedural step requiring the removal of the casing
              casing studs and might cause damage to the studs, the pump shaft,
studs. Removal of the back pull-out section is obstructed by the
              the motor shaft, or the coupling hubs. This item has been discussed
casing studs and might cause damage to the studs, the pump shaft,
            with the licensee.
the motor shaft, or the coupling hubs. This item has been discussed
        e.   There are two alignment screws on the pump that are used to align
with the licensee.
            the pump shaft with the motor shaft. These screws, once the pump is
e.
            properly aligned, are maintained in their proper positions during
There are two alignment screws on the pump that are used to align
            operation by tightening down the nut on each screw. However, the
the pump shaft with the motor shaft. These screws, once the pump is
              inspector observed that this had not been done and subsequently
properly aligned, are maintained in their proper positions during
              requested the maintenance personnel resolve the problem. In a
operation by tightening down the nut on each screw. However, the
            discussion with the System Engineer and the Assistant Maintenance
inspector observed that this had not been done and subsequently
            Engineer it was concluded that the vibration during operation could
requested the maintenance personnel resolve the problem.
            have shifted the alignment of the pump and, in turn, possibly caused
In a
            damage to the pump.
discussion with the System Engineer and the Assistant Maintenance
        f.   The RWCU pumps receive reactor water at a temperature of up to
Engineer it was concluded that the vibration during operation could
            575* F. This high temperature on the pump side may present a
have shifted the alignment of the pump and, in turn, possibly caused
            coupling alignment problem due to thermal expansion. This issue
damage to the pump.
              is not addressed in the coupling alignment section of Procedure
f.
              35.000.68.   The licensee is performing an analysis that shall
The RWCU pumps receive reactor water at a temperature of up to
              resolve this issue.
575* F.
        The inspector will perform additional inspection of this program area to
This high temperature on the pump side may present a
        determine if there is a widespread problem. This shall be accomplished
coupling alignment problem due to thermal expansion. This issue
        by further inspection of the adequacy of the licensee's maintenance
is not addressed in the coupling alignment section of Procedure
        supervision and performance of maintenance activities. The above
35.000.68.
        concerns in this program area are considered to be an unresolved item
The licensee is performing an analysis that shall
        (341/85029-03(DRP)) pending further evaluation as to whether these
resolve this issue.
        items are isolated cases are are more widespread.
The inspector will perform additional inspection of this program area to
!
determine if there is a widespread problem. This shall be accomplished
    6. Monthly Surveillance Observation
by further inspection of the adequacy of the licensee's maintenance
        The inspectors observed surveillance testing required by technical speci-
supervision and performance of maintenance activities. The above
        fications and verified that: testing was performed in accordance with
concerns in this program area are considered to be an unresolved item
        adequate procedures, test instrumentation was calibrated, limiting condi-
(341/85029-03(DRP)) pending further evaluation as to whether these
        tions for operation were met, removal and restoration of the affected
items are isolated cases are are more widespread.
        components were accomplished, test results conformed with technical
!
        specifications and procedure requirements and were reviewed by personnel
6.
        other than the individual directing the test, and any deficiencies identi-
Monthly Surveillance Observation
        fled during the testing were properly reviewed and resolved by appropriate
The inspectors observed surveillance testing required by technical speci-
        management personnel.
fications and verified that: testing was performed in accordance with
                                            10
adequate procedures, test instrumentation was calibrated, limiting condi-
tions for operation were met, removal and restoration of the affected
components were accomplished, test results conformed with technical
specifications and procedure requirements and were reviewed by personnel
other than the individual directing the test, and any deficiencies identi-
fled during the testing were properly reviewed and resolved by appropriate
management personnel.
10


                                _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _   .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
                                                                                    . . . .
.
    .
. . . .
  .
.
      The inspectors also witnessed portions of the following test activities:
.
      *
The inspectors also witnessed portions of the following test activities:
            Local Leakage Rate Testing for Penetration X-13A
*
      *
Local Leakage Rate Testing for Penetration X-13A
      *
*
            RHR Pressure Isolation Valve Leakage Test
RHR Pressure Isolation Valve Leakage Test
            Local Leakage Rate Testing for Penetration X35B,C,D,E,F
*
      No violations or deviations were identified in the review of this program
Local Leakage Rate Testing for Penetration X35B,C,D,E,F
      area.
No violations or deviations were identified in the review of this program
    7. Operational Safety Verification
area.
      The inspectors observed control room operations, reviewed applicable
7.
      logs, and conducted discussions with control room operators during the
Operational Safety Verification
      period from June 1 to June 30, 1985. The inspectors verified the
The inspectors observed control room operations, reviewed applicable
      operability of selected emergency systems, reviewed tagout records, and
logs, and conducted discussions with control room operators during the
      verified proper return to service of affected components. Tours of the
period from June 1 to June 30, 1985. The inspectors verified the
      reactor building and turbine building were conducted to observe plant                   l
operability of selected emergency systems, reviewed tagout records, and
      equipment conditions, including potential fire hazards, fluid leaks, and
verified proper return to service of affected components. Tours of the
      excessive vibrations and to verify that maintenance requests had been
reactor building and turbine building were conducted to observe plant
      initiated for equipment in need of maintenance.
l
      During the inspection period the inspectors verified that surveillance
equipment conditions, including potential fire hazards, fluid leaks, and
      tests were conducted, containment integrity requirements were met, and
excessive vibrations and to verify that maintenance requests had been
      emergency systems were available hs necessary.
initiated for equipment in need of maintenance.
      The inspectors, by observation and direct interview, verified that the
During the inspection period the inspectors verified that surveillance
      physical security plan was being implemented in accordance with the
tests were conducted, containment integrity requirements were met, and
      station security plan.
emergency systems were available hs necessary.
      The inspectors observed plant housekeeping / cleanliness conditions and
The inspectors, by observation and direct interview, verified that the
      verified implementation of radiation protection controls. During the
physical security plan was being implemented in accordance with the
      inspection, the inspectors walked down the accessible portions of the
station security plan.
      Low Pressure Coolant Irjection System and Core Spray System to verify
The inspectors observed plant housekeeping / cleanliness conditions and
      operability by comparing system lineup with plant drawings, as-built
verified implementation of radiation protection controls. During the
      configuration or present valve lineup lists; observed equipment condi-
inspection, the inspectors walked down the accessible portions of the
l     tions that could degrade performance; and verified that instrumentation
Low Pressure Coolant Irjection System and Core Spray System to verify
      was properly valved, functioning, and calibrated.
operability by comparing system lineup with plant drawings, as-built
      These reviews and observations were conducted to verify that facility
configuration or present valve lineup lists; observed equipment condi-
      operations were in conformance with the requirements established under
l
      technical specifications, 10 CFR, and administrative procedures.
tions that could degrade performance; and verified that instrumentation
was properly valved, functioning, and calibrated.
These reviews and observations were conducted to verify that facility
operations were in conformance with the requirements established under
technical specifications, 10 CFR, and administrative procedures.
I
I
      No violations or deviations were identified in the review of this program
No violations or deviations were identified in the review of this program
      area.
area.
    8. Allegation
8.
      An anonymous allegation was made to Region III stating that frequent door
Allegation
      checks by security personnel increase the potential for radiation exposure
An anonymous allegation was made to Region III stating that frequent door
      and therefore are contrary to ALARA guidelines.
checks by security personnel increase the potential for radiation exposure
                                                                                            '
and therefore are contrary to ALARA guidelines.
                                                                                11
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11


.
.
    This allegation was discussed with licensee personnel, who walked down
This allegation was discussed with licensee personnel, who walked down
    each vital area door which is routinely checked by security personnel.
each vital area door which is routinely checked by security personnel.
    The results of the licensee's review indicated that of all vital area
The results of the licensee's review indicated that of all vital area
    doors which are routinely checked by security personnel, only one is
doors which are routinely checked by security personnel, only one is
    located in a potential radiation area (between the auxiliary and off-gas
located in a potential radiation area (between the auxiliary and off-gas
    buildings), and none are located in high radiation areas. Entries into
buildings), and none are located in high radiation areas. Entries into
    areas posted and controlled as radiation areas are routine and are not
areas posted and controlled as radiation areas are routine and are not
    normally cause for significant ALARA concerns. No significant ALARA
normally cause for significant ALARA concerns. No significant ALARA
            ~
concern was identified in this case.
    concern was identified in this case.
~
    This allegation was not substantiated.
This allegation was not substantiated.
    No violations or deviations were identified in the review of this program
No violations or deviations were identified in the review of this program
    area.
area.
9. Systematic Assessment of Licensee Performance (SALP)
9.
    A mid-term SALP was performed prior to the Commission briefing for the
Systematic Assessment of Licensee Performance (SALP)
    full power license. The assessment period was frcs October 1, 1984, to
A mid-term SALP was performed prior to the Commission briefing for the
    June 30, 1985. Major activities which occurred during the assessment
full power license. The assessment period was frcs October 1, 1984, to
    period were the completion of preoperational testing, initial fueling and
June 30, 1985. Major activities which occurred during the assessment
    initial criticality. The SALP Board met on June 28, 1985, to review the
period were the completion of preoperational testing, initial fueling and
    assessments, rate each functional area, and make recommendations as to
initial criticality. The SALP Board met on June 28, 1985, to review the
    both licensee and NRC attention. The mid-term SALP will be presented on
assessments, rate each functional area, and make recommendations as to
    July 2, 1985, at Newport, Michigan, and documented in Inspection Report
both licensee and NRC attention. The mid-term SALP will be presented on
    50-341/85027.
July 2, 1985, at Newport, Michigan, and documented in Inspection Report
    No violations or deviations were identified in review of this program
50-341/85027.
    area.
No violations or deviations were identified in review of this program
10. Initial Criticality
area.
    The licensee achieved initial criticality on June 21, 1985, at 5:19 a.m.
10.
    EDT. The event was witnessed by the Deputy Regional Administrator -
Initial Criticality
    Region III, the assigned Section Chief, and a regional inspector in
The licensee achieved initial criticality on June 21, 1985, at 5:19 a.m.
    addition to the Senior Resident Inspector. Criticality was achieved
EDT. The event was witnessed by the Deputy Regional Administrator -
    within two steps of the predicted step of the rod pull sequence.
Region III, the assigned Section Chief, and a regional inspector in
    Additional details of this event are documented in Inspection Report
addition to the Senior Resident Inspector. Criticality was achieved
    50-341/85036(DRS).
within two steps of the predicted step of the rod pull sequence.
    No violations or deviations were identified in review of this program
Additional details of this event are documented in Inspection Report
    area.
50-341/85036(DRS).
11. Management Meetings
No violations or deviations were identified in review of this program
    A management meeting was held at Region III on June 14, 1985, at the
area.
    request of the licensee. The licensee discussed their proposed
11.
    reorganization of Nuclear Operations. The current organization is
Management Meetings
    considered to be structurally flat in that all organizations, with the
A management meeting was held at Region III on June 14, 1985, at the
    exception of Quality Assurance, report directly to the Manager of Nuclear
request of the licensee. The licensee discussed their proposed
    Operations. The licensee determined that the current organizational
reorganization of Nuclear Operations. The current organization is
                                        12
considered to be structurally flat in that all organizations, with the
                                                                              a
exception of Quality Assurance, report directly to the Manager of Nuclear
Operations. The licensee determined that the current organizational
12
a


  .
.
.
      structure was unwieldy to manage and has proposed a more streamlined
.
      organization. The new organization has been segregated into four
structure was unwieldy to manage and has proposed a more streamlined
      functional groups, Plant, Engineering, Services, and Regulation and
organization. The new organization has been segregated into four
      compliance, all reporting to the Manager of Nuclear Operations. This
functional groups, Plant, Engineering, Services, and Regulation and
      should result in a more manageable and responsive organization. In
compliance, all reporting to the Manager of Nuclear Operations. This
      addition, the new organization incorporates " institutional memory" in the
should result in a more manageable and responsive organization.
      proposed staffing.
In
      The licensee plans to implement the new organization after the issuance
addition, the new organization incorporates " institutional memory" in the
      of the full power license.
proposed staffing.
  12. Unresolved Items
The licensee plans to implement the new organization after the issuance
      Unresolved items are matters about which more information is required in
of the full power license.
      order to ascertain whether they are acceptable items, violations or
12.
      deviations. Unresolved items disclosed during the inspection are
Unresolved Items
      discussed in Paragraphs 2.b. (2), and 5.
Unresolved items are matters about which more information is required in
  13. Open Items
order to ascertain whether they are acceptable items, violations or
      Open items are matters which have been discussed with the licensee, which
deviations. Unresolved items disclosed during the inspection are
      will be reviewed further by the inspector, and which involve some action
discussed in Paragraphs 2.b. (2), and 5.
      on the part of the NRC or licensee or both. An open item disclosed
13.
      during the inspection is discussed in Paragraph 3.b.
Open Items
  14. Exit Interview
Open items are matters which have been discussed with the licensee, which
      The inspectors met with licensee representatives (denoted in Paragraph 1)
will be reviewed further by the inspector, and which involve some action
      on June 24, 1985,.and informally throughout the inspection period and
on the part of the NRC or licensee or both. An open item disclosed
      summarized the scope and findings of the inspection activities. The
during the inspection is discussed in Paragraph 3.b.
      inspect:+ also discussed the likely informational content of the
14.
      inspection report with regard to documents or processes reviewed by the
Exit Interview
      inspector during the inspection. The licensee did not identify any such
The inspectors met with licensee representatives (denoted in Paragraph 1)
      documents / processes as proprietary. The licensee acknowledged the
on June 24, 1985,.and informally throughout the inspection period and
      findings of the inspection.
summarized the scope and findings of the inspection activities. The
                                          13
inspect:+ also discussed the likely informational content of the
inspection report with regard to documents or processes reviewed by the
inspector during the inspection. The licensee did not identify any such
documents / processes as proprietary. The licensee acknowledged the
findings of the inspection.
13
}}
}}

Latest revision as of 09:47, 12 December 2024

Insp Rept 50-341/85-29 on 850601-30.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previously Identified Items,Including Fire Prevention/ Protection Program Implementation & Mgt Meetings
ML20132E499
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/26/1985
From: Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20132E498 List:
References
50-341-85-29, NUDOCS 8508020003
Download: ML20132E499 (13)


See also: IR 05000341/1985029

Text

.

.

U. 5. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/85029(DRP)

Docket No. 50-341

Operating License No. NPF-33

Licensee: Detroit Edison Company

2000 Second Avenue

Detroit, MI 48226

Facility Name: Fermi 2

Inspection At: Fermi Site, Newport, MI

Inspection Conducted: June 1-30, 1985

Inspectors:

P. M. Byron

M. E. Parker

D. C. Jones

R. A. Paul

Q L O /1A

Approved by:

G. C. Wright, Chief

-) /d b!

Projects Section 2C

Date

Inspection Summary

Inspection on June 1-30, 1985, (Report No. 50-341/85029(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of

licensee action on previous inspector identified items; independent inspection;

maintenance; surveillance; operational safety - ESF system walkdown; fire

prevention / protection program implementation; allegations, management meetings,

SALP, and initial criticality. The inspection involved a total of 323

inspector-hours onsite by four NRC inspectors, including 82 inspector-hours

onsite during off-shifts.

Results: Five open items, three license condition attachments (one of which

was also an open item), and one noncompliance were closed. Two unresolved and

one open item resulted from this inspection. Within the areas inspected, no

violations, deviations, or significant safety issues were identified.

8500020003 850729

PDR

ADOCK 05000341

0

PM

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DETAILS

9

1.

Persons Contacted

  • F. Agosti, Manager, Nuclear Operations
  • L.

Bregni, Licensing Engineer

J. DuBay, Director, Planning and Control

0. Earle, Supervisor, Licensing

R. Eberhardt, Rad-Chem Engineer

P. Fessler, Assistant Maintenance Engineer

i

  • E. Griffing, Assistant Manager, Nuclear Operations

W.'Jens, Vice-President, Nuclear Operations

4

W. Kaczor, Director, SAFETEAM (DECO)

R. Kunkle, Director, SAFETEAM (UTS)

S. Leach, Director, Nuclear Security

J. Leman, Maintenance Engineer

,

-L. Lessor, Advisor to the Superintendent, Nuclear Production

  • R. Lenart, Superintendent, Nuclear Production

,

R. Mays, Director, Project Planning

  • W. Miller, QA Supervisor, Operational Assurance

S. Noetzel, Site Manager

J. Nyquist, Assistant to Superintendent, Nuclear Production

G. Overbeck, Assistant Plant Superintendent

J. Plona, Technical Engineer

E. Preston, Operations Engineer

W. Ripley, Startup Director

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C. P. Sexauer, Nuclear Production Administrator

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G. Trahey, Director, Nuclear QA

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  • Denotes those who attended the exit meetings.

I

The-inspectors also interviewed others of the licensee's staff during

!

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this inspection.

2.

Followup on Inspector Identified Items

a.

-(Closed) Open Item (341/84003-06(DRSS)), and License Condition

Attachment 1, B.2.b:

Fabricate and install an intrinsic germanium

detector system post-accident collimator prior to exceeding ~five

l

percent power. The licensee fabricated several lead shield

collimators for accident condition use with the detector system,

'

and a calibration was performed for use with a multi-channel

'

analyzer. The licensee demonstrated the use of the collimators

for the inspectors. ,The inspectors also reviewed selected sections

of Radiological Engineering Report.No. 85-02, " Calibration of High-

Purity-Germanium Detector-for Use with~ Lead Collimators to Analyze

.High activity Post-Accident Samples."

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- b.

(Closed) Open Item (341/84039-01(DRP)), and License Condition

Attachment 1, B.1.a:

Accessibility of safety-related valves for

serviceability and manual operation. This item identified numerous

inaccessible safety-related valves that would require ladders or

platforms to operate, inspect, and maintain the valves.

(1) Concerning the manual operation of safety-related valves, the

licensee conducted a program that reviewed 217 safety-related

valves for accessibility. Of the 217 valves, 69 or 32 percent

required some form of accessibility aid

The results of this

accessibility program are as follows

Temporary scaffolding and lar.ders have been installed in

several cases which will proside an interim resolution

until permanent design chang ss can be implemented.

Portable stands, air hoists, and rolling platforms have

been chained and locked in strategic locations for the

other cases, which will provide a more permanent accessi-

bility. All operators have a key to the locks and have

been briefed on the operation and the locations of these

devices.

(2) Although the accessibility of safety-related valves for

operation was the primary issue of concern, the licensee

has developed a program which will address the issue of

serviceability. The program will consider the same 217

safety-related valves as the operability program, but from

a maintenance perspective. This will be accomplished through

the Engineering Evaluation Request (EER) process which shall

provide an evaluation and design for the permanent installation

of serviceability aids. This item requires further review and

evaluation and is considered an unresolved item (341/85029-

01(DRP)) pending completion of the serviceability program and

_

subsequent NRC inspection.

The licensee has demonstrated adequate accessibility to all con-

cerned safety-related valves. This satisfies the license condition

for criticality and this item is considered closed.

c.

(Closed) Open Item (341/84043-05(DRSS)): Complete Installation of

Standby Gas Treatment System (SGTS) sample line heat tracing prior

to exceeding five percent power. The heat tracing has been

installed, and the functional tests have been completed and

reviewed. The inspectors verified the installation of the heat

tracing.

3.

_

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.

d.

(Closed) Open Item (341/84043-10(DRSS)), and License Condition

Attachment 1, B.2.c:

Complete a comprehensive review of technical

adequacy, commitment compliance, necessary corrective actions and

associated training for the accident radioactive effluent release

quantification program prior to exceeding five percent power. The

licensee has completed the comprehensive review of technical adequacy

and commitment compliance and taken corrective action by revising

certain emergency response and plant procedures. These actions are

described in a licensee internal document entitled " Accident Radio-

active Release Quantification Program," which the inspectors reviewed.

Also completed are the approval of revised procedures and the training

of personnel on these revised procedures.

e.

(Closed) Open Item (341/85010-02(DRP)): Verification of the proper

operation of 24 single coil Target Rock solenoid valves. The 24

single coil Target Rock valves consist of 16 valves in the Post

Accident Sampling System, and 8 valves in the MSIV Leakage Control

System. Preoperational Test Procedure PRET.P3323.001, " Post

Accident Sampling System," included proper operation verification

for 14 of the valves. Plant Operations Manual (POM) Surveillance

Procedure 24.127.20, "MSIV Leakage Control System Local Valve

Position Indication Verification Test," included proper operation

verification for eight of the valves. POM Surveillance Procedure

43.401.383, " Local Leakage Rate Testing For Penetration X-215,"

included proper operation verification for two of the valves. All

single coil Target Rock solenoid valves operated properly. This

item is considered closed.

f.

(Closed) Noncompliance (341/85021-01(DRP)):

Inadequate implementa-

tion and review of Engineering Design Package EDP-1996 and the accompany-

ing Engineering Change Requests (ECR's) used to verify installation of

test, vent, and drain connection caps. This resulted in:

(a) the EDP

verification sheet not adequately reflecting the EDP and its accompanying

ECR's, (b) not all test, vent, and drain (TVD) caps being installed, and

(c) Plant Operations Manual (POM) Procedure 47.000.77, " Test, Vent, and

Drain (TVD) Cap and Plug Verification," omitting a penetration (X-220)

which consists of eight TVD caps. The following licensee corrective

action was implemented:

(1) The EDP verification sheet was corrected to incorporate all

revisions to EDP-1996 and the walkdown was reperformed. Also,

the EDP Implementation Plan was revised as required by POM

Procedure 12.000.64, "EDP Implementation." The individual who

incorrectly implemented this procedure was instructed to read

the procedure again and fully acquaint himself with all of its

i

requirements,

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.

(2) Completion of PN-21 No. 992725 and the revised verification

walkdown documents that all caps are now installed in accordance

with EDP 1996 and ECP's 1996-1 and 1996-2.

Surveillance Pro-

cedure 47.000.77 has been issued to administrative 1y control

the subject caps. Also, all associated plant drawings will be

updated in accordance with proper procedure to reflect as-built

conditions.

(3) The preparer and the technical reviewer reanalyzed all informa-

tion used to generate Procedure 47.000.77 and corrected the

procedural _ deficiency. They were then instructed by their

immediate supervisors of the importance of checking and

auditing large amounts of technical data systematically and

logically to preclude recurrence of this type of error. The

licensee has guidelines to follow in writing procedures which

are used to ensure correct technical and work content. The

individual was also instructed to acquaint himself with all

the requirements of this procedure.

The plant drawings shall be updated to reflect the as-built condition

of the TVD connection caps by November 30,1985. This item is con-

sidered closed.

g.

(Closed) License Condition 2.c.(12): Operability of the permanent

liquid radwaste treatment system prior to exceeding five percent

power. The licensee has completed the preoperational tests and

demonstrated that the system is operable. The system has been

turned over to operations. Several test exceptions which do not

affect the operability of the system remain open. A selected review

of preoperational test results (G1120.001 and G1125.001) was made by

the inspectors.

In addition the inspectors walked down several

sections of the liquid radwaste system.

h.

(Closed) License Condition 2.c.(16): Operability of the Post-

Accident Sampling System (PASS), THI Action Item II.B.3.

The

SER, Supplement No. 5 dated March 1985, states that the applicant

must demonstrate the capability of promptly obtaining a reactor

water coolant sample in the case of an accident, and that the PASS

meets all the requirements of Task Action Item II.B.3 and is

therefore acceptable. Since the SER was written, the licensee has:

demonstrated the PASS operable; approved POM procedure 78.000.14

which provides detailed instructions for the collection and analysis

of samples obtained by the PASS; provided training in the required

procedures; and performed a time and motion study to demonstrate

that PASS samples can be collected, transported, and analyzed in

accordance with NUREG 0737, Regulatory Guide 1.97, and GDC-19 dose

criteria. Selected review of the procedures, training records, and

the time and motion study was made by the inspectors.

5

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3.

Independent Inspection

a.

Temporary Solid Radwaste System

The licensee intends to use a portable solid radwaste treatment

system (NUS) to meet their technical specification requirements

until the completion of the preoperational tests and final approval

of the permanent solidification system. The system, which is

l

located in the radwaste building, is operable and will be used by

NUS contractor personnel in accordance with approved licensee

procedures. The licensee tested the portable system by solidifying

88 cubic feet of mixed bed bead resin from floor drain and waste

collector tanks to verify the system met the licensee acceptance

criteria. Selected results of these tests were reviewed by the

inspectors; no problems were noted. The inspectors also: discussed

the results of a licensee conducted ALARA review of the temporary

system with radwaste personnel; walked down the system to verify

installation; and observed selected components to identify potential

radiological problem areas. No significant problems were identified.

In a letter to the licensee from the NRC dated July 3, 1985, NRR

approved the licensee Process Control Program (PCP) for the

temporary radwaste system. Based on the acceptance of the PCP, the

demonstration test of the system, and the inspector's review of the

system, it appears the portable system will function as described in

the vendor's topical report (NUS Topical Report PS-53-00378) which

was submitted to the NRC by the licensee.

No violations or deviations were identified in the review of this

program area.

b.

Onsite Storage Facility (OSSF)

The licensee's onsite storage facility is described in Section 11B.1

of the FSAR. The facility is intended to provide interim storage

capacity for an amotint of waste which could be generated in five

years of plant operation. -During this inspection, and a previous

inspection (Report No. 50-341/85017(DRSS)), tours and discussions

concerning the OSSF were made. The tours were made to verify that

selected systems and components (including area radiation and

effluent monitors) were installed in accordance with the FSAR and to

identify any potential radiological problem areas. No problems were

noted.

During these tours and discussions with the licensee, special atten-

tion was given to the handling, decontamination, smearing, and

surveying of dry active and solidified waste drums; to the HVAC

,

6

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.

system; to the design features to ensure ALARA; and to the portable

solid radwaste system located in the truck bay area of the OSSF.

Radiation protection features of the OSSF include: protective

barriers around the stored waste to prevent uncontrolled releases to

the environment, remote handling of the waste drums, routing of all

potentially contaminated drains from the OSSF to plant liquid

radwaste system (the licensee verified each floor drain from the

OSSF is routed to the liquid radwaste system), and monitoring and

filtration of gaseous and particulate effluents.

One ALARA problem was noted in that no shielding had been provided

in the radwaste barrel readout area, nor had provisions been made to

read out the barrels remotely. The licensee stated they would

review the read out system and make improvements where feasible.

This program area requires further review and evaluation and is

considered an open item (50-341/85029-02(DRP))

No violations or deviations were identified in the review of this

program area.

c.

SAFETEAM

The Office of Investigation (OI) reviewed the investigative results

of SAFETEAM concerns based on issues raised during the licensing

process of another utility. June 11-13, 1985, OI investigators

reviewed the SAFETEAM investigators' packages for those concerns

which had been identified as wrongdoing. The wrongdoing concerns

had been forwarded to Region III as they had been identified. OI

investigators expanded the scope of their review when they returned

June 18-20, 1985, to include the completed investigative packages of

those concerns which the investigators deemed as potential wrongdoing

based on the description listed in the SAFETEAM computor printout.

The review included listening to the tapes, reading the transcription,

and reviewing the documentation in the packages.

The Director of OI, members of his staff, and NRR attended a

briefing at the site on June 19, 1985, by the licensee and the OI

investigators.

1

As a result of the OI concerns, a task force composed of individuals

from NRR, I&E, and Region III were at the site June 27 and 28, 1985,

to perform a more detailed investigation of SAFETEAM concerns for

technical merit and a comparison of the SAFETEAM off ort with that of

a similar undertaking by another utility.

The inspectors supported the OI and task force efforts.

In conjunction with this effort, the inspectors and the licensee

performed an inspection of the safety-related SAFETEAM findings at

the request of Region III. The inspectors reviewed the SAFETEAM

findings to determine if investigative effort adequately addressed

the concern and if the corrective action had been completed.

i

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Also, the licensee performed an independent inspection of the

SAFETEAM findings to verify adequacy of investigation and corrective

acti'on. Through discussions with the licensee, the licensee agreed

to review fifty percent of the hardware and software safety-related

concerns. The inspectors reviewed a sampling of the remaining fifty

percent of the safety-related concerns. The results of these

inspections will be documented in Inspection Report 50-341/85037.

No violations or deviations were identified in the review of this

program area.

d.

Operational Readiness

The licensee continues to make progress in its preparations for

power ascension. Fire detector installation, fire door inspection,

and the off gas system appear to be the most significant critical

path items.

Senior Region III management met with licensee management twice

during the inspection period to review the status of items affecting

initial criticality and power ascension, license conditions and

other areas of mutual interest.

No violations or deviations were identified in the review of this

program area.

e.

Independent Operational Readiness Assessment Inspection

A Region III team composed of experienced resident inspectors per-

formed an operational readiness inspection at Fermi 2 during

June 17-22, 1985. The purpose of the team inspection was to observe

the licensee's operations and review proceduras to identify strengths

and weaknesses. The team concluded that there were no significant

weaknesses observed and the plant was ready for power ascension.

This inspection is documented in Inspection Report 50-341/85031(DRP).

No violations or deviations were identified in the review of this

program area.

4.

Fire Prevention / Protection Program Implementation

The inspectors observed the progress of License Condition 9.e. which

requires that prior to exceeding five percent power, all early warning

fire detectors shall be installed and all fire door assemblies shall be

labeled or listed by a nationally recognized testing laboratory. The

inspectors additionally performed a more detailed examination of the

corrective action by the licensee on a sample basis to determine if the

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programmatic requirements were being met.

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No violations or deviations were identified in the review of this program

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area.

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5.

Monthly Maintenance Observation

Station maintenance activities of safety-related systems and components

listed below were observed to ascertain that they were conducted in

accordance with approved procedures, regulatory guides, and industry

codes or standards and in conformance with Technical Specifications.

The following items were considered during this review:

the limiting

conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedures and were

inspected as applicable; the procedures used were adequate to control

the activity; quality control records were maintained; activities were

accomplished by qualified personnel; parts and materials used were

properly certified; radiological controls were implemented; and fire

prevention controls were implemented.

The following maintenance activity was observed:

Reactor Water Cleanup (RWCU) Recirculation Pump Rotating

Assembly-Removal and Installation

Removal of RWCU recirculation pump "A" rotating assembly was performed

to replace seals and the impeller.

Plant Operations Manual (POM)

Maintenance Procedure 35.000.68, Revision 1 dated February 21, 1979,

"RWCU Recirculation Pump Rotating Assembly-Removal and Installation,"

was used to provide detailed instructions for removal, disassembly,

inspection, assembly, and installation of the RWCU pump. The inspectors

witnessed portions of this maintenance and identified several areas of

concern.

a.

Sections 7.1.4.1 through 7.1.4.4 of Procedure 35.000.68 describe

the steps used in draining the bearing housing oil. This was to be

done prior to the removal of the back pull-out section of the pump.

However, this was not done, resulting in the oil draining out onto

the floor during transfer to the rolling cart, and oil draining out

onto the rolling cart which, in turn, tracked the oil as it was

rolled to the workshop.

b.

Sections 7.1.7 and 7.1.8 and Reference 3.10 (POM Procedure

32,000.06, " Rigging") of Procedure 35.000.68 provide instructions

for the use of. a chain hoist and suitable sling. The hoist and

sling are used to support the back pull-out when the casing stud

nuts are removed and to facilitate simplified removal of the back

pull-out section. However, the maintenance personnel transferred

the back pull-out section to the rolling cart by hand. This

resulted in three men lifting and carrying the heavy and awkward

pump to the cart with oil draining significantly (see preceding

paragraph). Also, Procedure 35.000.68 requires that reference 3.10,

POM Procedure 32.000.06 " Rigging," is to be "used".

Section 3.0,

" Rigging Preplanning," of this procedure states "... determine the

weight of the load." The inspectors observed that the licensee did

not observe this requirement of the procedure.

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c.

The note on page 3 of Procedure 35.000.68 states, " Procedure steps

may be performed out of sequence with the prior approval of the

DECO Maintenance Foreman (as a minimum). This statement is

applicable until fuel load." However, section 7.5.11 which states. .

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"to refill the bearing house with Shell Vitrea Oil," was performed

af ter Sections 7.5.12 and 7.5.13.

Therefore, the procedure was

performed out of sequence which is a failure to adhere to procedural

requirements.

d.

There is no procedural step requiring the removal of the casing

studs. Removal of the back pull-out section is obstructed by the

casing studs and might cause damage to the studs, the pump shaft,

the motor shaft, or the coupling hubs. This item has been discussed

with the licensee.

e.

There are two alignment screws on the pump that are used to align

the pump shaft with the motor shaft. These screws, once the pump is

properly aligned, are maintained in their proper positions during

operation by tightening down the nut on each screw. However, the

inspector observed that this had not been done and subsequently

requested the maintenance personnel resolve the problem.

In a

discussion with the System Engineer and the Assistant Maintenance

Engineer it was concluded that the vibration during operation could

have shifted the alignment of the pump and, in turn, possibly caused

damage to the pump.

f.

The RWCU pumps receive reactor water at a temperature of up to

575* F.

This high temperature on the pump side may present a

coupling alignment problem due to thermal expansion. This issue

is not addressed in the coupling alignment section of Procedure

35.000.68.

The licensee is performing an analysis that shall

resolve this issue.

The inspector will perform additional inspection of this program area to

determine if there is a widespread problem. This shall be accomplished

by further inspection of the adequacy of the licensee's maintenance

supervision and performance of maintenance activities. The above

concerns in this program area are considered to be an unresolved item

(341/85029-03(DRP)) pending further evaluation as to whether these

items are isolated cases are are more widespread.

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6.

Monthly Surveillance Observation

The inspectors observed surveillance testing required by technical speci-

fications and verified that: testing was performed in accordance with

adequate procedures, test instrumentation was calibrated, limiting condi-

tions for operation were met, removal and restoration of the affected

components were accomplished, test results conformed with technical

specifications and procedure requirements and were reviewed by personnel

other than the individual directing the test, and any deficiencies identi-

fled during the testing were properly reviewed and resolved by appropriate

management personnel.

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The inspectors also witnessed portions of the following test activities:

Local Leakage Rate Testing for Penetration X-13A

RHR Pressure Isolation Valve Leakage Test

Local Leakage Rate Testing for Penetration X35B,C,D,E,F

No violations or deviations were identified in the review of this program

area.

7.

Operational Safety Verification

The inspectors observed control room operations, reviewed applicable

logs, and conducted discussions with control room operators during the

period from June 1 to June 30, 1985. The inspectors verified the

operability of selected emergency systems, reviewed tagout records, and

verified proper return to service of affected components. Tours of the

reactor building and turbine building were conducted to observe plant

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equipment conditions, including potential fire hazards, fluid leaks, and

excessive vibrations and to verify that maintenance requests had been

initiated for equipment in need of maintenance.

During the inspection period the inspectors verified that surveillance

tests were conducted, containment integrity requirements were met, and

emergency systems were available hs necessary.

The inspectors, by observation and direct interview, verified that the

physical security plan was being implemented in accordance with the

station security plan.

The inspectors observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. During the

inspection, the inspectors walked down the accessible portions of the

Low Pressure Coolant Irjection System and Core Spray System to verify

operability by comparing system lineup with plant drawings, as-built

configuration or present valve lineup lists; observed equipment condi-

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tions that could degrade performance; and verified that instrumentation

was properly valved, functioning, and calibrated.

These reviews and observations were conducted to verify that facility

operations were in conformance with the requirements established under

technical specifications, 10 CFR, and administrative procedures.

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No violations or deviations were identified in the review of this program

area.

8.

Allegation

An anonymous allegation was made to Region III stating that frequent door

checks by security personnel increase the potential for radiation exposure

and therefore are contrary to ALARA guidelines.

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This allegation was discussed with licensee personnel, who walked down

each vital area door which is routinely checked by security personnel.

The results of the licensee's review indicated that of all vital area

doors which are routinely checked by security personnel, only one is

located in a potential radiation area (between the auxiliary and off-gas

buildings), and none are located in high radiation areas. Entries into

areas posted and controlled as radiation areas are routine and are not

normally cause for significant ALARA concerns. No significant ALARA

concern was identified in this case.

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This allegation was not substantiated.

No violations or deviations were identified in the review of this program

area.

9.

Systematic Assessment of Licensee Performance (SALP)

A mid-term SALP was performed prior to the Commission briefing for the

full power license. The assessment period was frcs October 1, 1984, to

June 30, 1985. Major activities which occurred during the assessment

period were the completion of preoperational testing, initial fueling and

initial criticality. The SALP Board met on June 28, 1985, to review the

assessments, rate each functional area, and make recommendations as to

both licensee and NRC attention. The mid-term SALP will be presented on

July 2, 1985, at Newport, Michigan, and documented in Inspection Report

50-341/85027.

No violations or deviations were identified in review of this program

area.

10.

Initial Criticality

The licensee achieved initial criticality on June 21, 1985, at 5:19 a.m.

EDT. The event was witnessed by the Deputy Regional Administrator -

Region III, the assigned Section Chief, and a regional inspector in

addition to the Senior Resident Inspector. Criticality was achieved

within two steps of the predicted step of the rod pull sequence.

Additional details of this event are documented in Inspection Report

50-341/85036(DRS).

No violations or deviations were identified in review of this program

area.

11.

Management Meetings

A management meeting was held at Region III on June 14, 1985, at the

request of the licensee. The licensee discussed their proposed

reorganization of Nuclear Operations. The current organization is

considered to be structurally flat in that all organizations, with the

exception of Quality Assurance, report directly to the Manager of Nuclear

Operations. The licensee determined that the current organizational

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structure was unwieldy to manage and has proposed a more streamlined

organization. The new organization has been segregated into four

functional groups, Plant, Engineering, Services, and Regulation and

compliance, all reporting to the Manager of Nuclear Operations. This

should result in a more manageable and responsive organization.

In

addition, the new organization incorporates " institutional memory" in the

proposed staffing.

The licensee plans to implement the new organization after the issuance

of the full power license.

12.

Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

deviations. Unresolved items disclosed during the inspection are

discussed in Paragraphs 2.b. (2), and 5.

13.

Open Items

Open items are matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. An open item disclosed

during the inspection is discussed in Paragraph 3.b.

14.

Exit Interview

The inspectors met with licensee representatives (denoted in Paragraph 1)

on June 24, 1985,.and informally throughout the inspection period and

summarized the scope and findings of the inspection activities. The

inspect:+ also discussed the likely informational content of the

inspection report with regard to documents or processes reviewed by the

inspector during the inspection. The licensee did not identify any such

documents / processes as proprietary. The licensee acknowledged the

findings of the inspection.

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