IR 05000255/1982015

IE Insp Rept 50-255/82-15 on 820601-30.Noncompliance Noted: Failure to Perform Required Comparison of Auxiliary Feed Pump Flow Indications for May 1982

ML20055C149
Person / Time
Site:	Palisades
Issue date:	07/21/1982
From:	Boyd D, James Heller, Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055C140	List: IR 05000255/1982015 ML20055C139 ML20055C145
References
50-255-82-15, NUDOCS 8208100283
Download: ML20055C149 (10)

Text

__

,

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/82-15(DPRP)

Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Palisades Nuclear Generating Plant Inspection At: Palisades. Site, Covert, MI Inspection Conducted: June 1-30, 1982 Inspectors: B. . Jorgen en 7'M N J'

Y$ 7d/'82-Y . K. Heller Approved By: D.C.A d" d Boy/yd, hief 7- 2 / - 82.

Reactor Projects Section 1A Inspection Summary Inspection on June 1-30, 1982 (Report No. 50-255/82-15(DPRP))

Areas Inspected: Routine resident inspection program activities including review of plant trip; operations; maintenance; surveillance; reportable events; previously identified items; Region III request; and committee activities. The inspection involved a total of 177 inspector-hours onsite by two NRC inspectors including 50 inspector-hours onsite during off-shifts.

Results: Of the eight areas inspected, no items of noncompliance or devi-ations were identified in seven areas. One noncompliance was identified in the remaining area (Category 5 - component test frequency - Paragraph 5).

8208100283 820722 PDR ADOCK 05000255 G PDR

. . . - -

.

.

DETAILS 1. Persons Contacted

• R.' W. Montross, General Manager

'

J. S. Rang, Operations / Maintenance Superintendent

• H. J. Palmer, Technical Superintendent

'B. L. Schanger, Operations Supervisor

• G. H. R. Petitjesn, Technical Engineer

• R. E. McCaleb, Quality Assurance Superintendent S. Ghidotti, Shift Supervisor D. W. Kaupa, Shift Supervisor E. I. Thompson, Shift Supervisor A. F. Brookhouse, Shift Supervisor K. E. Osborne, Supervisory Engineer D. VanDenBerg, General Engineer J.

Dearth,

Instrument and Control Supervisor

• D. W. Rogers, Licensing Analyst

• W. L. Burmeister, Shift Technical Advisor R. W. Frigo, Shift Technical Advisor

• Denotes those present at Management Interview June 28, 1982.

In addition, several other members of the plant Operations, Maintenance and Technical staffs were contacted briefly.

2. Plant Trip The reactor tripped from hot standby at 4:45 a.m. on June 12, 1982, as a result of electrical " noise" on wide-range nuclear instrument NI-003, which feeds 2 of 4 reactor high startup rate channels. The plant had been taken off line earlier that morning for investigation of indicated oil leakage on primary coolant pump P-50D;.and for repairs to the tur-bine auto-stop oil pressure controls. The-inspector ascertained the status of the reactor and required safety systems by observation of con-trol room indicators and discussion with licensee personnel concerning plant parameters and emergency systems status. The inspector verified the completion of proper communications and reviewed the response actions

, of the licensee. All safety systems responded as expected and the plant was returned to critical following repairs at 4:19 p.m. on June 13, 1982.

No items of noncompliance or deviations were Identified.

3. Operational Safetv Verification The inspector made frequent control room observations, reviewed appli-cable logs and conducted discussions with control room operators during the month of June, 1982. The inspector verified the operability of

.

.

selected emergency systems, reviewed tagout records, and verified proper return to service of affected components.

Tours / observations were made in the following areas:

a. auxiliary building b. turbine building c. protected area fence d. containment and auxiliary roofs e. emergency electrical distribution system The inspector verified implementation of radiation protection controls; station security plan; plant housekeeping / cleanliness controls; observed plant equipment conditions, including potential fire hazards or fluid leaks; and verified that maintenance requests had been initiated for equipment in need of repairs.

Tko operations staff " shift meetings" were observed, as were an after-hours security contingency drill (June 16) and an after-hours fire drill involving response by the offsite local fire department (June 10).

The inspector's observations relating to the-fire drill were discussed with the responsible licensee manager, who had planned and scheduled a critique to review drill results.

During review of Shift Supervisor Logs, the inspector noted the licen-see had -ecured two primary coolant pumps while in the hot shutdown condition on May 13, 1982. Associated entries provided information on primary coolant system boron concentration (1147 ppm) and a boration on May 14, 1982 (some 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> later), to achieve 3.75% shutdown margin, as calculated by licensee procedure, to meet the shutdown margin require-ments of Technical Specification 3.10.1.b.

The inspector discussed the above item with the Operations and Technical Staffs on June 9, 1982, and a corrective action document was generated.

At the management interview the inspector informed the licensee that failure to obtain and maintain a 3.75% shutdown margin is a violation of Technical Specification 3.10.1.b and would be a category IV Noncom-pliance. The Reactor Engineer informed the inspector on July 6, 1982 that his review of this item and another calculation of the required boron concentration for a 3.75% shutdown margin revealed that no viola-tion had occurred. It appears the operators borated subsequent to an earlier plant trip (to assure 2.0% margin) without first obtaining the latest core burn-up information. The recalculation used actual burnup, but some conservatisms were credited, such that complianne to the required 3.'5% shutdown margin was shown.

. _ . . , . - - . _ - - -- ._

.

.

On July.8, 1982 the inspector expressed his concern to the plant management, since this was a preplanned evolution, that the proper boron concentration for the known burnup was not obtained and evaluated for 3.75% margin, prior to securing the pumps. This would have been intentional compliance and not accidental compliance.

The nature of the log entries suggests .that licensee personnel were aware an apparent inadequate shutdown margin had existed. The inspector reviewed corrective action records and found none' relating to this event.

Corrective action is to be initiated and documented for Technical Speci-fication violations (which this appeared to be) under the licensee's Administrative Procedures, Section 3.5.2. This was initiated following inspector discussion of the item with Operations Department management, as noted'above. Failure to initiate appropriate corrective action at the time of the event was discussed at the Management Interview.

On June 23, 1982, the licensee removed containment spray pump P-54A

, from service to remove and replace an improper brass / bronze valve on I

the pump discharge piping. The Technical Specifications permit such component inoperability provided " corresponding redundant components" are demonstrated operable by test. The definition of " corresponding redundant components" is unclear, but apparently refers to containment cooling components on the same emergency bus. On June 23, the licensee tested containment fan coolers on the same bus as P-54A, but not service water or component cooling water pumps also on the bus, and listed in the same Technical Specification. The only component not tested and not physically in service, was service water pump P-7C.

The failure to test P-7C service water pump prior to removing P-54A containment spray pump from service is considered an Unresolved Item.

(255/82-15-02) This item was discussed at the Management Interview and will be referred to NRR 'for in interpretation.

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.

. No items of noncompliance and no deviations were identified.

t i 4. Monthly Maintenance Observation i

Station maintenance activities of safety related systems and components listed below were observed / reviewed 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; functional testing and/or calibrations were performed prior to returning components or systems to service; quality

- . . .__ _ .-- -

=, - . . _ - . -- - .

.

-

.

.

I control _ records were maintained; activities were accomplished by 4 qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls-were implemented.

Work requests were reviewed to determine status _of outstanding jobs'

and to a3sure that priority is_ assigned to safety related equipment maintenance which may affect system performance.

The following maintenance activities were observed / reviewed:

! a. auto-stop oil pressure control valve replacement.

b. wide range nuclear instrument NI-003 repair

c. main feedwater pump-controls d. seal replacement and preventive maintenance on charging pump P-55A -

, Following completion of maintenance on the "A" charging pump, the in-spector verified that the system had been returned to service properly.

No items of noncompliance or deviations' were identified.

i 5. Monthly Surveillance Observation The inspector observed Technical Specifications required surveil-lance testing and other testing as listed below and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected com-

-

ponents were accomplished, that test results. conformed with Technical Specifications and procedure requirements _and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and. resolved by appropriate management personnel, L

a. Control Rod Drive Exercising per DWO-01 b. Sampling of Safety Injection Tanks per MC-11. During performance of this test the operator experienced some difficulty with the "B" Safety Injection Tank level. The operator correctly diagnosed the problem and initiated the appropriate corrective action documents, c. Delamination Testing of the Containment dome per approved contractor

procedure 12447/060-CP-1, Revision 1.

d. M0-20 charging pumps l

i

J

,- - ., , .n- - - _. --

.

.

e. M02 HPSI ("A" pump only)

f. -M0-19 containment spray pumps g. Shiftwise manual SPI readings with inoperable secondary datalogger The inspector reviewed a number of completed surveillance test packages-for the months of April through June, 1982, with findings as described'

below.

Technical Specification 4.1 (table 4.1.3, item 15) requires a monthly comparison of Auxiliary Feed Pump flow indications except when the plant is in cold shutdown. Steps 5.8 and 5.9 of procedure M0-24 perform this comparison. Discussion with Technical Staff. personnel indicated that this comparison is only performed during M0-24. The plant was in hot shutdown or above during May, 1982, except for the first three days, when the plant was in heatup; but the monthly flow comparison was not'done. Failure to perform the required comparison of Auxiliary Feed Pump flow indications for the month of May, 1982, is a violation of the Technical Specifications, Table 4.1.3, Item 15 (255/82-15-03).

The cover sheet to MO-24 states this test will be performed within.

one week following startup (in this case startup was defined as critical). It is not clear why startup is defined as critical when Technical Specification 3.5.1 requires the pumps to be operable when the primary coolant system is heated above 325*F. Engineering Manual (EM) 09-04 identifies that when a monthly surveillance test is not performed because of plant conditions, then the test must be performed within one week of return to normal plant operations. EM-09-04 defines normal operations to include periods during startup, hot shutdown, operations or cooldown. It appears that picking critical as the milestone to perform MO-24 is in disagreement with EM-09-04 and ASME Section XI. This was discussed at the Management Interview.

One item of noncompliance and no deviations were identified.

6. Licencee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfillcd, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Speci-fications.

a. (Closed) LER 81-04 " Masonry Walls." During review of masonry walls per IE Bulletin 80-11, the licensee determined that several walls did not meet the acceptance criteria. fee IE Inspection Report No. 50-255/82-09(DPRP) for a discussion of this item.

, 6

. . . . - - -

.

b. (Closed) LER 81-33 "Incore Alarms." During plant operation four incore alarms were received. The plant performed the required action of the Technical Specification (TS). The alarms annunciated when unusual flux shapes caused by power ascension reached the administrative limits; no TS violation occurred, c. (Closed) LER 81-37 " Low Pressure Safety Injection (LPSI) Check Valves." During maintenance on the four LPSI check valves the licensee fcund severe wear and missing internal parts. Licensee evaluation determined that high fluid velocity and turbulences, combined with valve design, created accelerated wear leading to valve failure. The valves were replaced with ones better suited for high velocities and turbulence. The licensee determined that this problem was not generic to similar make valves. This problem was found during cold shutdown and repairs made prior to returning the plant to service.

d. (Closed) LER 81-39 " Electrical and Environmental Qualification of Safety Related Equipment." During field inspection of safety related electrical equipment the licensee found numerous splices, terminal block and jumper wires that had questionable electrical qualification. The affected items were replaced / repaired during the 1981 refueling outage. The licensee believes the standards used during initial construction for splicing and making termina-tion did not meet current criteria. The licensee har. reviewed applicable electrical specifications and updated as required, e. (Closed) LER-81-44 " Improper Lineup For Draining Containment Sump."

During the 1981 refueling outage the shif t supervisor authorized draining the containment sump with a valve lineup that reduced the degree of containment isolation required during refueling. This item was identified as an item of noncompliance in IE Inspection Report No. 81-23 and closed in IE Inspection Repert No. 82-08(DPRP).

f. (Closed) LER 81-46 " Inoperable Fire Protection System Annunciator Panel." During a tour of the control room, an operator discovered that fire protection alarm panel was inoperable. One fire protec-tion alarm zone (cable spreading room) had a dead circuit; addi-tionally, alarms on the panel could not be reset. The licensee performed contingency actions required by the TS. The dead circuit was traced to a blown fuse. The inability to reset the panel was corrected by replacing a failed relay. Additionally, the licensee determined that operating procedures did not provide information on how to reset the C-47 panel. This information was incorporated into the operating procedures.

g. (Closed) LER 81-49 " Primary Coolant System Leakage." See Section 7.g for a discussion of this item.

h. (Closed) LER 82-04 " Oven Pressure Protection System (OPPS) Opera-tions." With the plant on shutdown cooling a safety injection

-

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _

.

actuation occurred, the resulting increase in PCS pressure caused operation of the OPPS. The safety injection was caused while transferring a preferred A.C. bus electrical power source.

1. (Closed) LER-82-07 " Inoperable Safety Injection and Refueling Water (SIRW) Tank Supply to the Charging Pumps." With the reactor in hot standby a volume control tank (VCT) low level signal :-multed in charging pump suction switching from the VCT to the SIRW. To stop boration of the PCS the charging suction was switched to the VCT and the SIRW tank supply to the charging system was overridden; a degraded condition permitted by TS. The VCT low level signal was the result of a blown fuse; the blown fuse was replaced. The charging pump transfer to the SIRW was returned to service within the cime levels of the TS.

No items of noncompliance or deviations were identified.

7. Followup Previously Identified Items The inspector reviewed licensee actions on the items identified below with findings as described, a. (Closed) Open Inspection Item (255/78-08-01): Failure to evaluate seismic adequacy for modifications of safety-related electrical /

control panels. The licensee identified facility changes and field changes for which seismic qualifications reviews had not been done or documented, and initiated the analyses through Action Item Record AIR-P-78-11. The project analysis of the whole panels in 1979 when original seismic qualification analyses could not be produced. The "as found" analyses were prepared by a contractor.

Before the licensee had accepted the contractor's conclusions, the entire question of electrical / control panel seismic capability came under scrutiny from the Systematic Evaluation Program (SEP)

being conducted for some licensees, including Palisades, by the NRC Of fice of Nuclear Reactor Regulation. The SEP review introduced broader questions concerning methods of analysis and magnitude of the seismic event for which qualification had to be demonstrated.

This broader scopo contributed to a licensee decision to " anchor" numerous panels to the floor in their respective locations and, in some cases, to the ceiling as well. Modifications involving panel anchoring were performed in 1980 and 1981, with completion of final work during the 1981 refueling outage. The licensee has concluded the subject panels, as modified, will neither slide nor tip over during a seismic event; nor will the internal components added during the modification process fail or become detached and damage other components. Remaining questions are to be addressed in the completion reviews conducted for the Systematic Evaluation Program.

b. (Closed) Open Inspection Item (255/787-02): Possible unmonitored failures of electrical breakers for safety-related equipment. The licensee was performed monthly inspections of the subject breakers for proper positioning for more than two years. In that no breaker

- -

, .-y

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

failures have been noted in this period, the liklihood of more than a single failure between monthly inspections (which will continue) is apparently small.

c. (Closed) Unresolved Item (255/78-23-01): Acceptance criteria for primary vs. secondary rod position deviation not met. The licensee's corrective action records (D-PAL-78-133, -137, -138,

-139, -140) were reviewed. The deviations resulted from failed secondary position indication reed stacks, which were replaced at the next refueling outage.

d. (Closed) Open Inspection Item (255/78-28-01): Security program items not covered by Quality Assurance Program. The licensee revised and received NRC approval on his QA Topical Report deleting implications of QA coverage for security activities. A separate corrective action program specific to security matters has been developed and implemented.

e. (Closed) Unresolved Item (255/78-30-02): " Temporary" records storage for up to two years. The licensee's practices were determined to be in noncompliance with requirements (255/80-20-04).

Corrective action will be reviewed in followup to the noncompliance item.

f. (Closed) Unresolved Item (255/79-20-03): Licensee apparently took credit for operability of equipment with surveillance test results exceeding acceptance criteria. The surveillance testing procedures were all reviewed and specific criteria clearly stated for determining operability as a function of test results. Further, the procedures specify how off-normal data must be dealt with. No repetition of the above circumstance has occurred in over two years, g. (Closed) Item of Noncompliance (255/81-28-05): The licensee determined that improper assembly of control rod drive mechanism number 03 resulted in primary coolant leakage in excess of Technical Specification limits. The licensee determined that failure of the maintenance crew to follow the assembly procedure was the root cause of the event. The licensee has imposed discipline for the employees primarily responsible, written a letter to all maintenance personnel reinforcing the importance of procedure compliance, and revised the administrative procedure to define what managent expects a workman to consider prior to signing a procedure.

No items of noncompliance or deviations were identified.

S. Regional Requests The resident inspector was requested by Region III to determine the manufacturer of installed bullet resistant fire doors and determine if the licensee had documentation specifically confirming that the doors had been tested and approved for fire resistance by a nationally recognized laboratory. It was determined the doors were manufactured

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

.

by Protective Materials Company, Inc. The licensee did not have documentation that specifically confirmed the doors, as supplied, had been tested and approved by a nationally recognized laboratory. The licensee agreed to consider the doors to be inoperable and has imple-mented applicable compensatory measures specified in the Technical Specifications. Resolution of the adequacy of bullet resistant fire doors is considered an open inspection item (255/82-15-04).

No items of noncompliance or deviations were identified.

9. Committee Activities This inspection included a review of licensee Plant Review Committee (PRC) activities. The inspector attended a meeting of the PRC on June 10, 1982, as a nonparticipant. The conduct of the meeting was observed to ascertain compliance to requirements for membership (qualifications and quorum), frequency, review process, and topics.

Further, the inspector reviewed minutes of PRC meetings for January -

June, 1982, for verification of compliance to the same requirements; and to verify implementation of PRC recommendations as appropriate.

One apparent administrative breakdown was identified wherein certain corrective action records were inconsistent with PRC recommendations for prevention of recurrence. On closer examination, the inspector found the licensee had already identified and corrected this situation with a result that the intentions of the committee were implemented, though somewhat tardily.

No itcms of noncompliance or deviations were identified.

10. Management Interview A management interview, attended as indicated in Paragraph 1) was conducted at the conclusion of the inspection on June 28, 1982. The following matters were discussed.

a. The inspector summarized the scope of the inspection.

b. The inspector's concerns relating to apparent violation of shutdown margin requirements were specifically discussed, with the inspector voicing additional concern that corrective action documentation was not initiated at the time of the event (Paragraph 3).

c. The noncompliance relating to auxiliary feedwater flow comparison frequency was specifically identified. The inspector noted the additional concern relating to scheduling of auxiliary feedwater testing generally - on the basis of availability of nuclear heat. The licensee noted some potential practical limitations and problems exist for testing without nuclear heat (Paragraph 5).

d. The unresolved item resulting from uncicar requirements on removal of containment - cooling - related components from service, was discussed (Paragraph 3).

10