Text

Insp Rept 50-341/85-37 on 850701-0930.Violation Noted: Inadequate Procedure for Preventive Maint of Diesel Generator & Failure to Perform intermediate-range Monitor Tech Spec Surveillance Testing
	ML20138J555
Person / Time
Site:	Fermi
Issue date:	10/25/1985
From:	Wright G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20138J542	List: IR 05000701/2009030; ML20138J538; ML20138J555;
References
	50-341-85-37, NUDOCS 8510290387
	Download: ML20138J555 (16)
	v • d • e

U. S. NUCLEAR REGULATORY COMMISSION

,.

REGION III

R: port No. 50-341/85037(DRP)

D:cket No. 50-341 License No. NPF-43

Licensee: Detroit Edison Company

2000 Second Avenue

Detroit, MI 48226

Facility Name: Fermi 2

Inspection At: Fermi Site, Newport, MI

Inspection Conducted: July 1 through September 30, 1985

Inspectors: P. M. Byron

M. E. Parker

D. C. Jones .,

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S. G. DuPont

J. M. Ulie

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Approved by: . ght, Clfief /, n -s s

R actor Projects Section 2C Date

Inspection Summary

Inspection on July 1 through September 30, 1985 (Report No. 50-341/85037(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of

licensee action on previous inspector identified items; licensee action on

10 CFR 50.55(e) items; headquarters requests; operational safety; maintenance;

surveillance; plant trips and operational events; systematic appraisal of

licensee performance; sustained control room and plant observation; startup

t:st witnessing and observation; independent inspection; and fire protection.

Tha inspection involved a total of 687 inspector-hours onsite by five NRC

inspectors, including 221 inspector-hours onsite during off-shif ts.

R:sults: Of the 12 areas inspected, no violations or deviations were

identified in 10 areas. Within the remaining areas, two violations were

identified (Paragraph 6 - inadequate procedure and Paragraph 8 - failure to

perform technical specification surveillance testing) which, due to plant

status, were of minor safety significance.

8510290387 851025

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DETAILS

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1. Persons Contacted

F. Agosti, Manager, Nuclear Operations

S. Booker, Assistant Maintenance Engineer

L. Bregni,. Compliance Engineer

J. Conen, Licensing Engineer

J. DuBay, Director, Computer Service & Information Systems

-0. Earle,~ Supervisor, Licensing

R. Eberhardt, Rad-Chem Engineer

P. Fessler, Maintenance Engineer

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E. Griffing, Assistant Manager, Regulation & Compliance

W. Jens, Vice-President, Nuclear Operations

S. Leach, Director, Nuclear Security

J. Leman, Superintendent, Maintenance and Modification Engineer

L. Lessor, Consultant to the Assistant Manager, Nuclear Production

R. Lenart, Assistant Manager, Nuclear Production

R. Mays, Outage Management Engineer

W. Miller, Supervisor, Operational Assurance

S. Noetzel, Assistant Manager, Nuclear Engineering

i J. Nyquist, Supervisor, Independent Safety Engineering Group

T. O'Keefe, Supervisor, Mechanical Civil Engineering

*G. Overbeck, Assistant Plant Superintendent, Startup

J. Plona, Technical Engineer

i E. Preston, Operations Engineer

l W.~ Ripley, Assistant Operations Engineer - Administrative

C. P. Sexauer, Nuclear Production Administrator

G. Trahey, Director, Quality Assurance-

R. Wooley, Acting Supervisor, Licensing

Denotes those who attended the exit meetings.

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

! this inspection.

l- 2. Followup on Inspector Identified Items (92701)

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a. (Closed) Open Item (341/84-07-01(DRP)): Failure of CR8 Rectifier in

Emergency Diesel Generators (EDGs). During the 24-hour test of EDG

No. 12 at 3250 kw, rectifier CR8 overheated. In earlier tests of

l EDGs 13 and 14, the same component (CR8) also overheated. The CR8

rectifier protected the EDGs from certain EDG output bus faults.

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The licensee's investigation of the CR8 rectifier failures concluded

< that the rectifiers were undersized and should be replaced by larger

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units. The licensee issued Nonconformance Report No. 84-1199 which

calls for the replacement of the present rectifiers with new

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selenium surge suppressors (rectifiers) which have thirty-two, 6"x8"

i' plates each. The inspectors verified completion of replacement by

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review of work orders PN21-991742, 991743, 991744, and 991745 for

EDGs 14, 13, 12, and 11 respectively. This item is considered

closed.

b. (Closed) Unresolved Item (341/84-20-13(DRP)): Purchasing inspection

report inadequacies. A DECO source inspection report dated May 27,

1975, for the Emergency Diesel Generators (EDG) revealed that

testing delays were encountered. A Deco inspector believed the

malfunctions should have been detected during preliminary inspection

and functional testing. Since control malfunctions and termination

deficiencies were documented in the May 27, 1975, report, the

licensee should have been alerted to the potential for problems.

However, the discrepancies were not identified until Checkout and

Initial Operation (CAIO) testing and not during installation.

Therefore, it appeared as though source inspections were not

adequate and the findings in the source inspection reports were

not followed properly.

To determine if there was a problem, the licensee looked at 1191

(100%) of the Purchase Inspection Reports (PIR) written before July

1981 on QA level I material. The purpose of the review was to

assure that all problems identified in the PIRs were resolved.

After reviewing the PIR, if there was an unresolved "open loop", an

investigation was conducted to determine if actions had been taken

for closure. This included a documentation search and, if required,

physical inspections to verify that work which was to be done had

been satisfactorily completed. When it was concluded that an item

lacked objective evidence of satisfactory resolution, a Deviation /

Event Report (DER) was issued. Of the 1191 PIRs, 12 DERs were

written covering 15 PIRs. The DERs will provide for adequate

resolution of the 15 identified "open loops."

The inspectors reviewed a sample of 10 PIRs that were determined

not to have an "open loop." The results of the review indicated

that the ' licensee's study provided adequate resolution of the

concern. It should also be noted that current QA program

implementing procedure prevents recurrence of this problem. This

item is considered closed,

c. (0 pen) Open Item (341/84-49-04(ORS)): The licensee was requested to

reassess each FSAR commitment to the NRC's fire protection criteria

and identify all areas of violation, deviation, and exception. By

letters dated February 4 and March 4, 1985, the licensee submitted

information regarding deviations from either previous commitments or

from NFPA codes to provide justification and resolution of certain

fire protection issues. By letter dated February 18, 1985, the

licensee indicated that a specific walkdown was to be conducted by a

third party knowledgeable in the NFPA codes by June 30, 1985, to

identify any potential deviations from the NFPA codes. This

walkdown is considered an item required to be performed prior to

exceeding five percent of full power. The licensee submitted for

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Region III information and review, the completed "NFPA Code Compliance

Summary Report" dated June 14, 1985, prepared by the licensee's

consultant. This summary report included a review of thirteen NFPA

codes and identified eight deviations with seven of the NFPA codes.

According to the report the identified deviations were dispositioned

for corrective action by an appropriate Detroit Edison procedure.

In discussions between the NRR fire protection reviewer and

Region III personnel on August 19, 1985, it was determined that

these deviations need not be submitted to NRR for formal review and

acceptance. Since the NFPA code reassessment has been performed

and only minor deviations were identified, the five percent

requirement is considered to have been met. However, this item

will remain open until the corrective actions covering the eight

deviations have been completed.

d. (Closed) Open Item 341/85014-02(DRS)): During plant tours, the

inspectors noted that a Conditional Release (CR) Card No. 83-41 was

attached to a relay inside the switchgear cubicles for RHR service

water pumps A and C. Further review revealed that the Conditional

Release had been closed. The presence of CR tags in the plant for

CRs that are actually closed could lead to confusion. Therefore,

the licensee was requested to determine which QA conditional release

numbers were still outstanding and ensure those were the only ones

still attached to their respective components.

The licensee corrective action included the issuance of a memo

from the Director of Nuclear Quality Assurance (NQA) and the

Superintendent of Nuclear Production to the NQA Staff and the

Nuclear Production Section Heads concerning the subject of

Conditional Release Tags. The memo requests the personnel to assist

in the removal of tags associated with closed CRs. This is to be

accomplished in the course of assigned activities by noting the tag

number and location of any CR tags observed. This information is

then phoned in to Procurement QA so that a check of the Conditional

Release Log can be done to verify that the CR is indeed closed and

the equipment is acceptable for use. Following verification, the

tag is then removed and mailed to Procurement QA for filing with the

original CR records. The corrective actions provide for the proper

handling of CR tags when they are found in the plant.

Implementation of the corrective action will resolve the problem of

closed CR tags in time and this item is considered closed.

e. sClosed) License Condition 2.C.9.(e): Fire Protection. License

Condition 2.C.9.(e) required the licensee to complete the

installation of all early warning fire detectors, have all fire door

assemblies labeled or listed by a nationally recognized testing

laboratory (unless accepted by NRR), and rehydro the fire protection

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yard piping prior to exceeding 5% power. See Inspection Report

50-341/85025 for additional details concerning this item.

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(1) Detectors

During a walkdown of several fire detecticn systems for

interference from mechanically induced air flows, the

inspectors noted three areas which did not strictly conform

to NFPA 72E. As corrective action, the licensee conducted

a study of Fermi 2's fire detection system to determine

conformance to NFPA 72E and committed to relocate affected

existing detectors and install additional detectors to meet

the requirements of NFPA 72E. As a result of the study,

50 existing detectors required relocation and 54 additional

detectors had to be added.

The inspectors visually verified the relocation of 16 detectors

and the addition of 17 new detectors as per the design

drawings. Also, the inspectors reviewed all Surveillance

Performance Forms (SPF) to verify proper operation of 100% of

the new and relocated fire detectors. No problems were noted

in either area. The licensee is continuing to update all

affected drawings. License Condition 2.C.9(e) regarding fire

detectors has been satisfied.

(2) Fire Doors

During a fire protection / safe shutdown capability inspection,

the inspectors observed several designated fire doors either

nothavinganUnderwritersLaboratories(UL)labelidentifying

the doors fire resistance capability or the doors had 1 1/2

hour UL labels affixed instead of the required 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months fire

rtsistive rating as stated in the FSAR. License Condition

2.C.9.(e) required the labeling or listing of all fire door

assemblies by a nationally recognized testing laboratory prior

to exceeding five percent of full power.

The licensee's corrective action included issuing a contract

to UL to investigate, evaluate, and fire test where necessary,

to assure the doors in question will satisfactorily perform

their intended fire protection function. To conform to

acceptable UL design criteria many fire door assemblies

required modifications such as filling screw holes where

signs had been removed, adding steel bar stock to the frame,

and installation of a sill plate on the floor in the door

assembly opening. Also, thirteen fire doors were replaced

with new doors. All UL required modifications were completed

for the applicable fire door / frame assemblies with the

exception of four doors. These four doors were approved

by NRR for exemption.

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The inspectors visually verified that all 55 fire doors and

their frames were properly labeled by UL. No problems were

noted and License Condition 2.C.9(e) regarding fire door

assemblies has been satisfied.

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(3) Hydrostatic Test of the Underground Fire Main

As documented in Inspection Report 50-341/84049, a review of

pre-operational test results indicated inconsistent pressures

and flows recorded for the ten year old underground fire main

system hydrastatic test. The licensee acknowledged the

inconsistendies in the test and agreed to retest the system at

200 psig. This was completed on May 31, 1985, and the measured

leakage rate was 253 gallons for two hours. NRR accepted the

licensee's hydrostatic test and License Condition 2.c.9.(e),

regarding the hydrostatic test was satisfied. Additional

details on this issue are contained in Inspection Report

50-341/85025(DRS).

3. Licensee Action on 10 CFR 50.55(e) Items (92700)

a. (0 pen) 50.55(e) Item 50-341/84-03-EE (Licensee No. 111): " Design

Deficiency on the Residual Heat Removal (RHR) Reservoir Freeze

Over." On December 28, 1983, water in the RHR reservoir which

serves as the ultimate heat sink, froze to a depth of two to three

inches. Safety-related Diesel Generator Service Water, Emergency

Equipment Service Water, and Residual Heat Removal Service Water f

(RHRSW) deep draft pumps take suction from these reservoirs. Ice

formed around the column of these pumps and had the potential to

rencer the pumps inoperable.

The RHR complex design did not provide an adequate method to prevent

freezinq of the reservoirs for the period between the end of

construction and initial plant operation. The licensee corrective

action originally was to run the Emergency Equipment Cooling Water

system and/or the Emergency Diesel Generators (EDGs), while the

unit is operating, to maintain the water temperature above 43*F.

While the unit is not operating, the decay heat from the reactor

core would supply adequate heat.

After discussions with NRC Region III and NRR staff, the licensee

made a decision to use a temporary auxiliary boiler to add any heat

necessary to prevent freezing of the RHRSW reservoirs. Therefore,

the EDG's would not be operated to provide heat to the reservoirs.

The licensee's compensatory measures were considered adequate for

the interim period. However

Nuclear Reactor Regulations g (thisNRR)item willresponse.

written remain open pending NRC

b. (Closed) 50.55(e) Item 50-341/85004-EE (Licensee No. 147),

" Additional Fire Dampers Required." By letter dated February 28,

1985, the licensee identified deficiencies in fire barriers between

fire zones in the Auxiliary Building. The Fire Hazards Analysis

! drawings identify the walls which are required to be fire barriers

but some drawings do not clearly indicate that a floor n.ay also be a

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fire barrier. Therefore, some HVAC ducts which penetrate floors

were not identified as crossing a fire barrier and the required

dampers were not installed. The licensee's corrective action

included:

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A drawing verification, which supplemented the walkdown

inspection, of the HVAC duct penetrations, pipe chases, and

other unusual . fire barrier configurations to determine if

other fire zones required additional barriers.

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The installation of six additional HVAC fire dampers and

one pipe chase fire barrier.

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The expansion or modification of the Fire Hazards Analysis

drawings to identify which floors, or parts of a floor, are

fire barriers.

The inspectors verified proper installation and noeration of the six

HVAC fire dampers and the pipe chase barrier. Also, the inspectors

verified that the Fire Hazards Analysis drawings are being revised

and expanded to illustrate complete fire zone boundaries including

floors, walls, ceiling, chases, and doorways. This item is closed. ,

4. Followup on Headquarters Requests (92704)

a. Commissioner Asselstine Tour

Commissioner Asselstine, with his technical assistant, the Deputy

Regional Administrator and members of his staff, accompanied by

senior licensee management and site management toured Fermi 2 on

July 1, 1985. The tour was conducted by the Senior Resident

Inspector and included individual discussions with licensed

operators and members of the shift staff by Commissioner Asselstine.

Commissioner Asselstine met with the resident staff and licensee

management prior to and subsequent to the tour.

b. Commission Briefing for the Full Power License

The Region III Deputy Regional Administrator, the Fermi 2 Section

Chief, and the Senior Resident Inspector were at headquarters

July 8-10, 1985, to as.est the NRR staff in their preparation of

the presentation for the Fermi 2 full power license briefing. The

emphasis of the Region III support focused around the completion of

license conditions, plant operational history and the SAFETEAM.

The staff briefed the Commissioners on July 9, 1985, regarding

the SAFETEAM and its effectiveness. The program's strengths and

weaknesses were identified. The findings of the resident,

Region III, and NRR/IE inspections were discussed.

The Commission voted on July 10, 1985, to grant Fermi 2 a full power

license after being briefed by IE, NRR, and Region III management.

The full power license was issued July 12, 1985.

l No violations or deviations were identified in this area.

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5. Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicaole logs

and conducted discussions with control room operators during the period

from July 1 to September 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

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 as 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

following systems to verify operability by comparing system lineup with

plant drawings, as-built configuration or present valve lineup lists;

observing equipment conditions that could degrade performance; and

verified that instrumentation was properly valved, functioning, and

calibrated.

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High Pressure Coolant Injection System

The inspectors also witnessed portions of the radioactive waste system

controls associated with radwaste shipments and barreling. On August 27,

1985, the inspector witnessed Radwaste Shipment No.85-007, the licensee's

first radwaste shipment. This shipment consisted of condensate polisher

resins, solidified in concrete with a total activity of approximately

8.5 millicuries. The inspectors observed radiation and contamination

surveys which were well within the limits established by the Department

of Transportation.

These reviews and observations were conducted to verify that facility

l 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 this area.

6. Monthly Maintenance Observation (62703)

Station maintenance activities of safety-related systems and components

listed below were observed to ascertain that they were conducted in

accJrdance with approved procedures, regulatory guides, and industry

codes or standards and in conformance with Technical Specifications.

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! The following items were considered during this review: the limiting

l conditions for operation were met while components or systems were

l removed from service; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedures and were

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inspected as applicable; the procedures used were adequate to control the

activity; quality control records were maintained; activities were

l accomplished by qualified personnel; parts and materials used were

properly certified; radiological controls were implemented; and fire

l prevention controls were implemented. Work requests were reviewed to

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determine status of outstanding jobs and to assure that priority is

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assigned to safety-related equipment maintenance which may affect system

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The following maintenance activities were observed:

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EDG-14 Lube Oil Filter and Oil Change

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Crossover Cable Fire Stop Seal Maintenance

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The inspectors witnessed the lube oil filter replacement on EDG No. 14.

! After the filters were removed from the filter housing, there was still

approximately an inch of oil in the bottom that had to be cleaned out.

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The procedure did not specify the type of material to be used for cleanup

and as such the maintenance personnel opted to use paper disposable wipes.

The paper rags promptly dissolved in the oil, thus rendering the EDG

systemDivisionIIinoperableduetoforeignmater{alcontaminationof

the lube oil system

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10 CFR Appendix B, Criterion V, as implemented by the licensee's

procedure QAPR 5, requires that procedures appropriate to the

circumstances shall be used to control activities affecting quality.

Contrary to the above, the licensee's procedure governing preventive

maintenance on the diesel generator was not appropriate in that it failed

, to specify the type of material to be used in cleaning activities

l resulting in the diesel generator being inoperable (341/85037-01).

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In response to the event the licensee issued Deviation / Event Report (DER)

! No. NP-85-0392 and hung a Deficiency Notice tag No. 1827 on the system.

l Also, Maintenance Instruction MI-M136 " Emergency Diesel Generator -

l Preventive Maintenance" was revised to include a caution against using

unauthorized materials in the filter housing and specifying cloth rags

for cleanup. The inspector has reviewed the licensee's corrective

actions and considers them adequate.

i No othe.r violations or deviations were identified in this area.

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7. Monthly Surveillance Observation (61726)

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The inspectors observed surveillance testing required by technical

specifications and verified that: testing was performed in accordance

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with adequate procedures, test instrumentation was calibrated, limiting

conditions for operation were met, removal and restoration of the

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! 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 identified during the testing were properly reviewed and

resolved by appropriate management personnel.

The inspectors witnessed portions of the following test activities:

- Start and Load Test - Emergency Diesel Generator (EDG) No. 13

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DGSW and DF0T Pump and Valve Operability Test - (EDG) No. 13

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Division I Core Spray System Pump and Valve Operability Test

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High Pressure Coolant Injection Pump Operability and Flow Test

at 1000 psig and Valve Operability

The inspector observed the performance of the HPCI surveillance and

verified that the surveillance was conducted in accordance with an

approved procedure (POM 24.202.01). The purpose of tne surveillance was

to verify operability after maintenance. However, the HPCI system was

not made operable because the system valve lineup was not performed for

an additional two shifts.

Because HPCI had not been made operable, a later shift entered a

Technical Specification Limiting Condition of Operation (T.S. 3.0.3)

when the Low Pressure Coolant Injection cross-connection valve was

shut for a surveillance. The licensee recognized the condition within

approximately 30 minutes and the operator opened the valve per the

shift supervisor's direction, thus removing the unit from the LC0.

The HPCI valve lineup was performed and the HPCI system was made

operable.

This is another example of the operating shift not being aware of

equipment status.

No violations or deviations were identified in this area.

8. Plant Trips and Followup of Operational Events (93702)

a. Plant Trips

Following the plant trips on June 28, July 1, July 5, and July 9,

September 3, and September 27, 1985, the inspectors ascertained the

status of the reactor and safety systems by observation of control

room indicators and discussions with licensee personnel concerning

plant parameters, emergency system status., and reactor coolant

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chemistry. The inspectors verified the establishment of proper

communications and reviewed corrective actions taken by the

licensee.

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All systems responded as expected, and the plant was returned to

operation for startup testing on June 29, July 2, and July 6,

July 10, September 13, and September 28, 1985, respectively.

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b. Operational Events

On September 9, 1985, at 6:00 p.m. the licensee discovered that

they failed to perform the weekly channel functional test for

Intermediate Range Monitors (IRMs) B, G, and H within the

prescribed time interval. IRM B became inoperable on September 6,

1985, at 7:30 a.m. due to failure to perform the channel functional

test. IRM G became inoperable on September 6, 1985, at 12:32 p.m.

and IRM H became inoperable on September 6, 1985, at 6:28 p.m. for

the same reason. The licensee was unaware that the IRM surveillances

had expired and were, therefore, considered inoperable. The licensee

had the IRM surveillances scheduled but the surveillances were not

performed. They were subsequently completed on September 7, 1985.

IRM B functional surveillance was successfully completed at 2:46 a.m.,

IRM G at 1:58 a.m. and IRM H at 5:48 a.m.

As a result of two out of the four IRMs in Division II (IPM B & H)

being inoperable, the licensee was in T.S. 3.3.1 action statement

and should have placed the trip system in the tripped condition

within one hour. The action statement also required the licensee to

verify all insertable control rods to be inserted in the core and

lock the reactor mode switch in shutdown position within one hour.

Both IRMs were inoperable for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 18 minutes during which

time the plant was in cold shutdown.

The failure to perform the surveillance in a timely manner is

considered a violation of T.S. 4.3.1.1 (341/85037-02).

9. Systematic Appraisal of Licensee Performance (990218)

The Systematic Appraisal of Licensee Performance (SALP) was given to

the licensee at Fermi on July 2, 1985. The appraisal period for SALP VI,

October 1, 1984, through June 30, 1985, was abbreviated in order that

an appraisal be made prior to the issuance of the full power license.

The Deputy Regional Administrator and members of his staff made the

presentation to senior licensee management with public attendance. The

licensee's overall performance was average with above average performance

in three functional areas and below average performance in one functional

area. The SALP is documented in Inspection Report 50-341/85027.

10. Sustained Control Room and Plant Observation (71715)

The licensee restarted the reactor on August 10, 1985, after being in an

outage since July 23, 1985. The reactor was shut down after the South

Reactor Feed Pump turbine failed. The inspectors increased their

coverage of control room activities such that control room activities

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were monitored on a three shift basis August 9-15, 1985. The resident

! effort was supplemented by a Region III inspector commencing August 12,

1985. The inspection focused on all aspects of control room activity

such as briefings and turnovers, log keeping, communications, operator

response, and administrative controls.

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The inspectors identified several weaknesses and oteserved conditions

which had been previously identified. The most significant items were:

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The tagging system was weak.

- The plant status system was inadequate.

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The work order system was weak.

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Preventative maintenance must have a higher priority.

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The numbar of open work orders was excessive.

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The operating crews needed to function as a team.

The inspectors met with licensee management to discuss their concerns.

The licensee's response to these concerns was addressed in their

September 10, 1985, presentation in Region III.

No violations or deviations were identified in this area.

11. Startup Test Witnessing and Observation (72302)

The inspectors reviewed portions of startup test procedures, reviewed

procedure results completed to date, toured the areas containing system

equipment, interviewed personnel, and observed test activities of those

startup tests identified below.

During this review, the inspectors noted that the latest revision of the

test procedure was available and in use by crew members, the minimum crew

requirements were met, the test prerequisites were met, appropriate plant

systems were in service, the special test equipment required by the

procedure was calibrated and in service, the test was performed as

required by approved procedures, temporary modifications such as jumpers

were installed and tracked per established administrative controls, and

test results for the tests observed by the inspectors indicated that

acceptance criteria were met.

a. Scram Time Testing

The inspectors observed the performance of portions of STUT.HUC.005,

Revision 2, " Control Rod Drive System - Scram Timing": Insertion

time testing of Sequence A and Sequence B control rods at 600 psig,

800 psig, and 950 psig (rated pressure).

b. Insert / Withdrawal Timing and Friction Testing

The inspectors observed the performance of portions of STUT.HUA.005,

Revision 2, " Control Rod Drive System - Insert / Withdrawal Timing"

and STUT. HUB.005, Revo 'on 2, " Control Rod Drive System - Friction

Testing." These te*cs were performed at rated pressure (950 psig)

during initial heatup.

No violations or deviations were identified in this area.

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12. Independent Inspection (92706)

a. Valve Accessibility

License Condition Attachment 1, 8.1.a, required the licensee to

provide accessibility to safety related valves for manual operation.

Compensatory measures were subsequently implemented and the item was

closed. The corrective action included placing portable stands, air

hoists, and ladders in strater. locations. These accessibility

aids were to be locked in their established storage areas and all

O.srators would have keys and be briefed on the operation and

locations of these devices. It was believed that since only

g a tors have the correct key to unlock these dev':es, adequate

control would be maintained providing the operato n properly

returned the devices after use. However, the in pectors have

identified several instances of air hoists and ladders missing from

their storage location. After further investigation it is believed

that Operations may be unlocking the devices for use by other

departments, using the devices themselves and not returning them to

the storage area, and there may also be keys held by unauthorized

personnel. This is an open item (50-341/85037-02(DRP)) pending

review of licensee corrective action for maintaining control of

valve accessibility aids.

b. Open PN-21s (Work Orders)

The licensee has consistently had a large number of open PN-21s

(Work Orders) in the control room. There were 423 open orders as

of June 30, 1985, and the number peaked to 481 on July 28, 1985.

The inspectors consider that the magnitude of open PN-21s contributed

to some of the recent problems such as the status of equipment. The

inspectors also consider the number of the open PN-21s to be

unacceptable. The inspectors have observed several PN-21s that

were still open three months after the work had been completed.

The inspectors brought their concerns to the licensee who took

corrective action by making a concertive effort to complete the

required actions and to closecut the PN-21s.

The licensee had 345 open PN-21s on September 29, 1985, and work

had been completed on 198 of these. This results in 147 actual

open PN-21s. The licensee's goal is to have a maximum of 120

active PN-21s with half being preventative maintenance items.

The licensee is including the control qf open PN-21s in their

Operations Improvement Program. The inspectors believe that the

licensee must make the effort to successfully control the number of

open PN-21s in order to reduce the probability of equipment status

problems.

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c. Temporary Solid Radiowaste System

The Safe Energy Coalition (SECO) requested additional information

concerning the temporary NUS solid radiowaste equipment to be used

at Fermi from the Director of NRR at the February 20, 1985, meeting

held at Fermi (Inspection Report 50-341/85013). The NUS process is

considered to be proprietary and SECO was told that they could not

review the information and NRR would review the process for

effectiveness. Subsequent to this meeting, SEC0 and NRR came to an

agreement that members of SEC0 could review the NUS submittal in the

presence of the Senior Resident Inspector (SRI) provided that those

who reviewed the document sign a nondisclosure agreement. The NUS

document was sent to the resident office on April 18, 1985, and SEC0

-was notified that it could be reviewed at Fermi 2.

SEC0 made arrangements with the SRI to view the documents at

1:00 p.m. on July 2, 1985. Four members of SEC0 reviewed the

documents in the presence of the SRI on July 2, 1985. SEC0

requested that the SRI retain the documents as other members of

SECO wanted to review the documents. The resident office had no

other communication with SEC0 regarding the NUS documents and

returned them to NRR on July 29, 1985.

d. Turbine Roll

The licensee successfully rolled the main turbine to synchronous

. speed (1800 rpm) on September 30, 1985. Both inspectors were in

the control room during the event. No significant problems were

revealed during the run.

e. SAFETEAM

This inspection into_the SAFETEAM activities is a result of concerns

raised during the licensing process of another utility. This

inspection is a followup of an initial inspection documented in

Inspection Report 50-341/85029(DRP). The inspectors reviewed the

SAFETEAM findings to determine if investigative effort adequately

addressed the concern and if corrective action had been completed.

At the same time, the licansee performed an independent inspection

of the SAFETEAM finding", D verify adequacy of investigation and

corrective action. Througn 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 inspectors reviewed over 10% of the total hardware and software

safety-related concerns identified to the SAFETEAM.

During the inspection, DECO expanded their review to include

additional concerns, resulting in the licensee looking into

approxinately 67% of the safety-related concerns and over 50% of

the non-safety related hardware concerns. As a result of the

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additional inspections, there was an overlap betw=s ....s _t.o review

and that performed by the NRC resulting in approximately 85% of the

concerns reviewed and inspected by the NRC being previously reviewed

by DECO.

The inspection identified some problems in the system which are

believed to be isolated examples and programmatic in nature. They

included the following:

-

Inadequate interviews (unable to channel the problem; vague

generic concerns)

Packages did not address the whole concern

"

-

Packages incomplete (inadequate documentation)

-

Packages should have been provided with additional closure

information (i.e. 50.55(e)'s, NRC Inspection Reports, Duke

Inspection Reports, DECO Reports)

-

Investigators unable to receive engineering support

Although some flaws were identified in the SAFETEAM, an overall good

effort went into the SAFETEAM project. With the supplemented and

augmented inspection effort by both Deco and the NRC, we were able

to reach the same conclusions, although the inspectors found it

difficult for the SAFETEAM to reach their conclusions on some

concerns based upon the originally available documentation in

the packages.

Overall the inspectors believe the packages were complete and well

documented and the concerns were adequately addressed. The licensee

has since committed to improve the weaknesses identified in the NRC

and Deco inspections.

The results of this inspection and DECO inspection were provided to

NRC Region III and were used as the basis for regional input to the

Commission briefing on July 9, 1985. See paragraph 4.b. for

additional information on the Commission briefing.

f. Bypass Crack Piping

The licensee observed leakage in the East Steam Bypass line on

September 17, 1985, while operating at 4.1%. The licensee removed

insulation and observed cracks in the 30-inch bypass line and cracks

in hanger retainer and lug welds. Damage appeared to be restricted

to locations to which hangers or' snubbers were attached. Subsequent

investigation by the licensee revealed similar occurrences in the

t' West Steam Bypass Line. Licensee actions are being monitored by

Region III specialists and additional information will be documented

in a subsequent inspection report.

No violations or deviations were identified in this area.

I 15

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13. Fire Protection (64704)

License Condition 2.C.9.(e): Inspection Report 50-341/85025,

Paragraph 4.a., License Condition 2.C.9(e), " Detectors", last paragraph,

stated, in part, "The fire detector study will be docketed...." The word

" docketed" should be changed to " approved by managemrint." The licensee

indicated that the word " official" as used in the telephone conversation

on July 3, 1985, was not intended to imply " docketed" but " approved by

. management".

No violations or deviations were identified in this area.

14. Open Items

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

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

on the part of the NRC or licensee or both. Open items disclosed during

the inspection are discussed in Paragraphs 2 and 12.

15. Exit Interview (30703)

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

on July 29, September 30, 1985, and informally throughout the inspection

period and summarized the scope and findings of the inspection

activities. The inspectors also discussed the likely informational

content of the inspection report with regard to documents or processes

reviewed by the inspectors during the inspection. The licensee did not

identify any such documents / processes as proprietary. The licensee

acknowledged the findings of the inspectijn.

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