IR 05000341/1987014

Insp Rept 50-341/87-14 on 870331-0504.Violations Noted: Failure to Assure That safety-related Equipment Not Placed in Proximity to Masonry Block Walls & Utilize Operations Manual Procedure

ML20214J842
Person / Time
Site:	Fermi
Issue date:	05/20/1987
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214J823	List: IR 05000341/1987014 ML20214J821 ML20214J830
References
50-341-87-14, NUDOCS 8705280213
Download: ML20214J842 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/87014(DRP)

Docket No. 50-341 Operating License No. NPF-43 Licensee: Detroit Edison Company 2000 Second Avenue Detroit, MI 48226 Facility Name: Fermi 2 Inspection At: Fenni Site, Newport, Michigan Inspection Conducted: March 31 through May 4, 1987 Inspectors: W. G. Rogers M. E. Parker

D. S. Brinkman

$& N k- 8-M -U Approved By: E. G. Greenman, Deputy Director Division of Reactor Projects Date

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Inspection Summary Inspection on March 31 through May 4, 1987 (Report No. 50-341/87014(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of -

LER followup, followup of events, operational safety, maintenance, surveillance, plant trips, report revie Results: Two violations were identified (failure to assure that safety-related equipment was not placed in proximity to masonry block walls which could fall down, Paragraph 2.c., and failure to utilize latest P0M procedure during T.S. required surveillance, Paragraph 6.b.). One unresolved item was identified (Paragraph 5.b.). No deviations or open items were identifie :

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DETAILS 1. Persons Contacted Detroit Edison Company F. Abramson, 0perations Engineer

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F. Agosti, Vice President, Nuclear Operations L..Bregni, Compliance Engineer

• S. Cashell, Licensing G. Debner, Startup Engineer, Test Phase 0. Earle, Technical Engineer, Nuclear Production

• S. Frost, Licensing

.R. Kelm, Director,-Nuclear Security J. Korte, Nuclear Security Supervisor, Plans'and Programs

• J. Kowalewski, Maintenance

• R. Lenart, Plant Manager, Nuclear Production L. Lessor, Consultant to the Phnt Manager, Nuclear Production

• R. May, Superintendent, Maintenance and Modifications W. Orser, Vice President, Nuclear Engineering J. Plona, Operations Support Engineer

• E._Preston, Director, Plant Safety

• T. Randazo, Director, Regulatory Affairs L. Simpkin, Director, Nuclear Engineering F. Sondgeroth, Licensing Engineer, Licensing

• B. R. Sylvia, Group Vice President, Nuclear Operations

• G. Trahey, Director, Quality Assurance

• W. Tucker, Superintendent, Operatiors U. S. Nuclear Regulatory Commission

• Parker, Resident Inspector

• Rogers, Senior Resident Inspector

• Denotes those who attended the exit meeting on May 7, 1987.

The inspectors also interviewed others of the licensee's staff during this inspectio . Licensee Event Reports Followup (92700) Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent

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recurrence had been accomplished in accordance with Technical i Specification (Closed) LER 85029 CRD Pump Trip and Manual Scra (Closed) LER 85033 Reactor Trip Due~to Bypass Valve Controller

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(Closed) LER 85033-01 Reactor Trip Due to Bypass Valve Controller Malfunctio (Closed) LER 85033-02 Reactor Trip Due to Bypass Valve Controller Malfunctio (Closed) LER 85041 Blockage of HPCI Lube Oil Lin (Closed) LER 85041-01 Blockage of HPCI Lube Oil Lin (Closed) LER 85043 Division I Core Spray /RCIC Room Cooler De-energize (Closed) LER 85044 Control Center HVAC Out of Service When Require (Closed) LER 85054 HPCI Isolation during Surveillance Testin (Closed) LER 85056 Failure to Perform Leak Test After Maintenance on Hydrogen Thermal Recombinc (Closed) LER 85066 Reactor Trip Due to West Bypass Valve Closin (Closed) LER 85072 Containment Isolation - Incorrect Fuses Pulle (Closed) LER 86009 Torus Water Management System Isolation Caused by Personnel Erro In addition to the review criteria stated above, the LERs were reviewed for potential violations of regulatory requirement The results of that review identified a violation of Limiting Conditions for Operation was associated with LERs 85041 and 85041-01. This violation occurred during the same time frame and was of the same type as the violations identified in Inspection Report No. 50-341/8504 As indicated in Paragraph 9.d of Inspection Report N /86019,/85040the Report No. 50-341 escalated adequately enforcement address actions this violation and of noInspection-citation will be give b. (0 pen) LER 87-007-00, ESF/RPS Actuation due to voids in Residual Heat Removal Piping. The licensee identification of the actuation, the followup review of why it occurred, and the designated corrective actions are documented in DER 87-09 The licensee followup review was broad, thorough, and conducted by utility management. Upon conclusion of the review, a verbal presentation was made to the inspector including recommended corrective action Initial reaction was that some procedural violations had occurred )

during the event but the licensee's corrective actions adequately

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addressed the situation. As such the violations were reviewed under the criteria of 10 CFR 2, Appendix C.V.A, and determined to meet all-the applicable criteria as stated below:

• The violations were licensee identifie * Violation corrective actions within the last two years would not necessarily have corrected these violation * The violations were procedural adherence matters which meet 10 CFR 2, Appendix C, criteria for Severity Level IV violation * The initial followup review and recommended corrective actions were thorough and broad as documented in DER 87-095. .The corrective actions to address these violations were:

(1) Briefing o.' all licensed shift personnel of the even (2). Review operations policy concerning actions to be tasen when steps are bypassed in a procedur (3) Review production aolicy concerning the shift su)ervisor!s

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respons1bilities w'len plant conditions impact scledul (4) Attempt to run the event on the simulator and demonstrate other methods available for cooldown with no heat sink availabl (5) Conduct a problem analysis of recurring check valve indication problems and valve test operator problem (6) Conduct an engineering review of the feasibility of installing throttle valve capability in the RHR drop le (7) Revise standard o)erating procedure, S0P 23.205, associated with Ri Verification of completion of all corrective actions shall be done under followup to LER 87-00 * The licensee submitted 50.72 and 50.73 reports to the NRC inside the specified time frames. -Additionally, the inspector was immediately notified of the event and promptly given a presentation of the results of the followup review. The inspector did note that the 50.73 report did not contain all the corrective actions of the DER and the inspector suggested that the LER be revise c. During the inspection period,-the inspector performed a followup on

. issued an outstanding in December licensee of 198 Thedeviation / event DER reported report, DERcond a nonconforming 86-167,ition on

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e the construction of masonry block walls which couid impair their ability to withstand an earthquake. At the time of identification, the licensee performed a walkdown of the walls to identify safety-related equipment which could be impacted by wall failur Of those walls calculation whichwas DC4479 could impact safety-related performed equipment,in to evaluate wall collapse moredesign detail. The results of the calculation were that none of these walls would fall down in a seismic event. Calculations were not performed on the rest of the walls which did not have safety-related equipment close enough to be impacted should the wall fall dow Based on this information, the licensee considered the walls

" operable" and all immediate corrective action taken. Long-term corrective action was determined to be modification of all the block walls removing the nonconforming condition. The inspector inquired of the licensee whether the long-term corrective action had been taken. It had not. The inspector then inquired what interim measures had been established by the licensee to assure that safety-related equipment was not placed in aroximity to those walls that had not been analyzed under DC4479. Tie licensee stated that no controls had been established. Failure to establish those controls constitutes a violation (341/87014-01(DRP)) of 10 CFR 50, Appendix B, Criterion XVI, in that inadequate corrective actions were specified for a nonconforming condition in the facilit After conversation with the inspector, the engineering personnel immediately performed a walkdown of all the unanalyzed walls and observed that no safety-related eguipment had been installed in the area since the previous walkdown in December, issued a memo to the plant manager stating the prohibited areas of safety-related equipment installation, and issued a memo to design personnel on the prohibitd areas. Actions were also taken to analyze the block walls which were not a part of DC4479. On April 10, 1987, the analysis, DC4479A, was completed with the conclusion being that none of these block walls would fall down in a seismic even Based upon this conclusion the previous memos were cancelled deleting any prohibited eguipment installation areas arouna block walls. Upon discussion with the licensee, the plant safety personnel performed a review of all outstanding DERs to determine if similar conditions existed with other nonconforming conditions. The results of the review were that no other situation was identified. As af the end of the report period, the licensee has addressed all the salient points of the violation except for those actions which will be taken to prevent recurrence of this violation in the futur No other violations or deviations were identified in this are . Followup of Events (93702)

During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the events onsite with licensee and/or other NRC officials. In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the

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licensee was taking prompt and appropriate actions, that activities were conducted within regulatory requirements and that corrective actions would prevent future recurrence. The specific events are as follows:

April 06, 1987 - Reactor scram.as a result of an I&C personnel erro April 08, 1987 - Michigan'DNR notification of one gallon gasoline spil April.09, 1987 - Offsite sulfuric acid spil April 10, 1987 - Unusual Event, both HPCI and RCIC inoperabl April 21, 1987 - Premature failure of motor termination box adapters on-room cooler motor April 26, 1987 - Reactor scram as a result of leaking isolation valv No violations or deviations were identified in this are . Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicabl logs, and conducted discussions with control room operators during the period from March 31 thrcugh May 4, 1987. 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

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excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security pla 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 Division I and II Standby Gas Treatment 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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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 procedure From April 6 through 10, 1987, extensive control room observation was

performed by a Restart Team membe These observations encompassed portions of day and afternoon shift During this' time frame, licensee strengths were noted in procedure adherence, temporary change execution, i

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and turnovers. Weaknesses were noted in minor housekeeping deficiencies and the lack of aggressiveness in which the operating shift pursued water leakage contamination determination and spill containmen No violations or deviations were identified in this are . Monthly Maintenance Observation (62703) Station maintenance activities on 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 specification 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 initiatir.g the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; 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 implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed:

• Rod Sequence Control System Rod Sequence Mode Select Switch Replacemen * Motor-to-Motor Termination Box Adapter Changeout for Room Cooling Fan Motor * Main Steamline Repair Following completion of maintenance on the room cooling fan motors, the inspectors verified that these systems had been returned to service properl On April 21, 1987, while in cold shutdown, the licensee identified that the motor-to-motor termination box adapters for 11 of 12 safety-related cooling fan motors exhibited premature failur These room coolers are required to support Technical Specification related emergency safety features (ESF) and electrical switchgear distribution equipment. The motor adapters do not appear to have had a structural analysis completed at the time of installatio The failures appear to be due to the effect of weight and vibratio No motor has failed operation at any time and all motors were

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declared provisionally operable by the license The licensee has upgraded the design to incorporate a new aluminum motor termination box adapte The inspector reviewed the licensee's immediate corrective actions to ensure continued system operability and observed implementation of the upgraded aluminum motor termination box adapters per Engineering Design Package (EDP) 7278, " Motor Termination Box Adapters."

The apparent failure to perform an adequate seismic and structural evaluation'on the original motor adapters is considered an unresolved item (50-341/87014-02(DRP)) which will be evaluated by Region III Division of Reactor Safety during a routine followup inspectio No violations or deviations were identified in this are . Monthly Surveillance Observation (61726) The inspectors observed surveillance testing required by Technical Specifications and verified that: testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions 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 identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed portions of the following test activities:

• 24.000.02 Attachment 2 and 3 - Shiftly, Daily, Weekly, and Situation Required Surveillance * 24.106.01 Control Rod Drive Operable Control Rod Chec * 24.203.05 Division II Core Spray System Pump and Valve Operability Tes * 24.204.06 Division II Low Pressure Coolant Injection and Torus Cooling / Spray Pump and Valve Operability Tes * 44.010.126 APRM C Channel Functional Tes On April 14, 1987, while observing surveillance testing on the reactor

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heat removal (RHR) system, the inspector questioned the control room nuclear supervising operator (CRNS0) on why he was not adhering to the surveillance procedure. After discussion with the individual,

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it was apparent that the surveillance test was being performed with a superseded revision. Plant Operations Manual (P0M) 24.204.06,

" Division II LPCI and Suppression Pool Cooling / Spray Pump and Valve Operability Test," Revision 11 dated March 31, 1987, was being utilized versus Revision 12 dated April 13, 198 Significant changes to POM 24.204.06 were implemented in Revision 12 to incorporate instrument setpoint tolerances previously identified as a programmatic deficiency. This revision allowed the use of both Division I and Division II full flow test lines to verify RHR system flow. When this was brought to the attention of the CRNS0 and the nuclear assistant shift supervisor, further surveillance testing was stopped and the system was secured utilizing Revision 12 to P0M 24.204.06. In reviewing the circumstances surrounding the event, the inspector learned that the surveillance procedure was issued from Production Information Center (PIC) the day before (April 13,1987) in preparation for surveillance testing on April 14, 198 P0M 21.000.01, Revision 32 dated April 7, 1987, states in Paragraph 5.2.1, "Only approved drawings and procedures of the latest revision are to be used. Operations personnel are responsible for ensuring that the proper documents are being utilized." Nuclear Operations interfacing Procedure 11.000.49, Revision 6 dated December 27, 1986, states in Paragraph 5.5, " Users of documents in the performance of activities affecting quality or safety shall use only the most current information at the appropriate control level."

This is implemented by the user verifying through the Plant Operations Manual Index, that the latest revision to the procedure is available for use. As such, the licensee failed to verify through the P0M Index that the latest revision was available prior to commencing surveillance testing on April 14, 1987. This is a violation of 10 CFR 50, Appendix B, Criterion VI (50-341/87014-03(DRP)).

Subsequent review of the P0M Index identified that it had been updated to reflect the latest revision (Revision 12) in effect for P0M 24.204.0 Review of the controlled set of procedures in the control room identified that P0M 24.204.06 had been updated to incorporate Revision 1 c. On April 17, 1987, during a routine 31-day surveillance of the standby liquid control system storage tank baron concentration, the licensee determined that the concentration of boron in solution was outside the limits specified in Technical Specification 3. The actual results received varied between 14.2% and 14.7%.

The Technical Specificatiod s limit is 13.8%. Technical Specification 3.1.5 requires the standby liquid control system to be operable in Operational Conditions 1, 2, and 5 with any control rod withdrawn. At the time of discovery on April 17, 1987, the reactor was in cold shutdown and standby liquid control system was not required to be operabl E . 4 -

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1The previous sample ~taken on March 21,~1987,-yielded a concentration of 13.6%. This sample _was.taken after increasing the concentrationi of, boron due toia' loss-of boron. solution in the storage tank (see-Inspection Report No. 50-341/87012, Paragraph 9,'for details).- lAll subsequent boron analysis res'ults'have conflicted with the results obtained on March 21, 1987. -This is due to the different methods used to-determine the boron concentration employed by the license ;

The first method, analysis by plasmaLspectrometry, yielded th in-spec result of 13.6%. The second method, titrimetric' analysis Lyielded the results of 14.2 - 14.7%. The licensee hasLdetermined 1the~ titrimetric analysis to be:more reliable and.has supported.this j conclusion by specific gravity measurements.~

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As identified above, at the time of discovery onl April 17,.1987,.the reactor was'in cold shutdown and standby liquid control system was not required to-be operable. However,-between the time period of

April 3, 1987,.and-April 12,11987,_the licensee entered operational'

conditions-1-and 2 ontwo occasions without the boron concentration'-

within.the limits of Technical Specification 3.5.L -This is considered a violation of Technical Specifications 3.5.1'and 3. _

As a result of _the corrective ' actions taken by the-licensee, the inspector reviewed the circumstances surrounding this event to determine.if a Notice of-Violation wasLwarranted.~ The inspector reviewed the violation and the licensee's corrective actions against the criteria of 10 CFR 2,-Appendix C.V.A., and determined that the criteria were met. Specifically:

(1) The high boron solution' concentration was identified by the license (2). The high boron concentration'was evaluated and determined not to have compromised operation of the: standby-liquid control system as the temperature of the-system was maintained ~high enough to prevent precipitation of the boron solution.'

(3) The event was determined not to be 10 CFR 50.72 repartable but was-immediately identif_ied to the. inspectors.- The licensee has

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taken action to initiate a 10 CFR 50.73,' Licensee Event Repor .

(4) Immediate corrective actions have been initiated per the Deficiency / Event Report process and: include night orders requiring the boron solution concentration to be analyzed using the titrimetric method until chemistry procedures are updated toreflectthepreferredmethod." Additionally [plantprocedures-will be modified to require an. independent' verification of boron

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concentration any time additio~ns are made to the standby liquid control storage tan '

(5) Corrective actions to previous violations would not havel specifically addressed this situatio i

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. . Report Review (90713)

During the inspection period, the inspector reviewed the licensee's Monthly Operating Report for March 1987. The inspector confirmed

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that the information provided met the requirements of Technical Specification 6.6.A.3 and Regulatory Guide 1.1 No violations or deviations were identified in this are . Plant Trips (93702)

Following the plant trips on April 6, 1987, 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 statuc and reactor coolant chemistr The inspectors verified the establishment of proper communications and reviewed the corrective actions taken by the license All systems responded as expected, and the plant was returned to operation on April 7, 198 No violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more information is required.in order to ascertain whether they are acceptable items, violations or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph . Exit Interview (30703)

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

on May 7, 1987, 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 proprietar The licensee acknowledged the findings of the inspectio