IR 05000255/1982028
| ML20028E681 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/13/1983 |
| From: | Boyd D, James Heller, Holzmer M, Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20028E672 | List: |
| References | |
| 50-255-82-28, NUDOCS 8301280115 | |
| Download: ML20028E681 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
i Report No. 50-255/82-28(DPRP) ! l Docket No. 50-255 License No. DPR-20 l Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201
1 Facility Name: Palisades Nuclear Generating Plant ! Inspection At: Palisades Site Covert, MI Inspection Conducted: November 1-30, 1982 ' b5 4f ' % f /g-65
Inspectors: B. L. Jorgensren /D Y h J. K. Heller /'~ d ' # O t/f(,,g7 gl64._.
I / 'het ' /-/5'- 6 3 Approved By: D. C. Boyd, hief Reactor Projects, Section 2.B , Inspection Summary Inspection during November 1-30, 1982 (Report No. 050-255/82-28(DPRP)) Areas Inspected: Routine Resident Inspection Program activities including: j Licensee Actions on Previous Inspection Findings; Operations; Surveillance; ! Maintenance; Reportable Events; Preparations for Cold Weather; Design Changes ' and Modifications; Audit Activities; and Miscellaneous and Independent Inspec-ti n Activities. The inspection involved a total of 212 inspector-hours onsite ! by three NEC inspectors including 45 inspector-hours onsite during off-shifts.
. Results: No items of noncompliance or deviations were identified in seven l nine areas inspected. One noncompliance was identified in each of the remaining i two areas.
(Level V-failure to implement Administrative Procedures - Operations, i Paragraph 3) and (Level V - failure to implement Administrative Procedures - ' Maintenance, Paragraph 6.e).
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. ' DETAILS 1.
Perscns Contacted
- R. W. Montross, General Manager
- J. S. Rang, Operations / Maintenance Superintendent
- R.
P. Margol, Senior Engineer
- R. M. Krich, Technical Engineer
- K. E. Osborne, Maintenance Superintendent R. A. Fenech, Senior Engineer R. L. Muzzi, General Engineer G. W. Ford, Senior Engineer
- B. L. Schaner, Operations Supervisor K. M. Farr, Plant Public Affairs Director A. F. Brookhouse, Shift Supervisor D. W. Langschwager, Shift Supervisor D. W. Kaupa, Shift Supervisor A. S. Kanicki, Shift Supervisor R. D. Story, Plant Maintenance Planner
- R. A. Vincent, Administrator, Nuclear Activities Plant Organization
- D. W. Rogers, Licensing Analyst
- J.
A. Greenwood, Quality Assurance Administrator R. E. McCaleb, Quality Assurance Superintendent
- Denotes those present at the Management Interview
+J.
F. Firlit, Director QA - Nuclear Operations +H. M. Esch, General Supervisor, Quality Engineering +E.
H. Browder, Section Head, Audit Programs +W.
E. McConnell, Section Head, Corrective Action + Denotes persons contacted at the corporate office in Jackson, Michigan.
Numerous other members of the plant Operations / Maintenance and Technical staffs were contacted briefly.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance (50-255/80-20-08): Failure to audit all [ aspects of the Quality Assurance (QA) Program in 1979 and 1980.
The inspector verified that audits were performed which covered all aspects of the QA p.ogram in 1981. Audits in 1982 covering all aspects of the QA program were either performed or scheduled. The licensee has implemented a program for scheduling of audits which appeared to provide for adequate coverage of audit requirements, b.
(Closed) Open Item (50-255/80-20-09): Authority and responsibility delegated to the QA function. The inspector verified by interviews l with QA management and auditors that communications with plant per-sonnel and management were satisfactory. QA personnel also felt that l the importance accorded by management and plant personnel to QA find-ings was appropriate.
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. 3.
Plant Operatinns The inspector observed control room operations, reviewed applicable logs and conducted discussions with control operations personnel during November, 1982. Operability status of selected safety-related systems was routinely verified.
Proper shift manning and oversight were also verified in accordance with Technical Specifications.
Tours of accessible plant areas in the turbine and auxiliary buildings were conducted. The inspector reviewed plant equipment conditions for proper operations and verified maintenance requests had been initiated where appropriate.
Primary coolant system leakage into the safety injection header continued in November, -causing increased level in the "B" safety injection accumulator.
. As a result accumulator level and boron concentration Limiting Conditions for Operations were exceeded on ;several occasions, however, Technical Specification Action requirements were met in all cases. The cause of the Icakage is a small check valve leak (on the order of 0.2 gpm) which is not considered repairable under existing plant conditions. Licensea actions to restore ar.cumulator parameters were considered appropriate in each instance. The licensee has requested a revision to the specifications involved from the NRC Division of Reactor Licensing. The inspector veri-fled the licensee's calculations for total primary system Icakaga and for primary leakage into the safety injection header.
Plant housekeeping conditions were found to exhibit continued improvement.
Implementation of radiation protection controin and site security measures was routinely observed. One radwaste truck awaiting shipment was inde-pendently surveyed.
The inspector observed plant fire brigade response to a fire alarm on November 4, 1981, which involved a malfunctioning electrical space heater in an onsite contruction area. The situstion was corrected in minutes without outside assistance.
The inspector reviewed proper safety-related system lineups using licensee system checklists.
Portions of the following were inspected: a.
CL 3.7 Engineered Safeguards System Checklist b.
CL 12.5 Auxiliary Feedwater System Checklist c.
CL 15.1 and CL 15.2 Service Water System d.
CL 19 Service Air System Checklist e.
CL 22.1 Diesel Generators Checklist f.
CL 22.2 Fuel Oil System Checklist
. . The review of checklist CL 12.5 identified one valve (MV-709 FW) for which the service description and required position were in error. This appeared to result from failure to properly revise the checklist after a facility modification (discussed further in Paragraph 8 below). Examination of the licensco's historical checklist records showed that the licensee identi-fled the checklist error on the checklist Exception Sheets in August 1982, but had not taken corrective actions. Licensee Administrative Prcaedure 4.0, Paragraph 5.4.5.B requires review of checklist Exception Sheets and revision as necessary to correct checklist errors.
Implementation of Administrative Procedures is a requirement of Technical Specification 6.8.1.a by reference to Regulatory Guide 1.33, Appendix A.
Failure to correct the known error on CL 12.5 is an example of noncompliance with the referenced Technical Specifications (50-255/82-28-01).
No other items of noncompliance or deviations were identified.
4.
Surveillance The inspector reviewed surveillance activities to ascertain compliance to requirements or scheduling. Test activities were observed in progress or reviewed to verify compliance to requirements relating to procedures, removal from and return to service, personnel qualifications, and documen-tation. The following test activities were observed: M0-24 " Auxiliary Feedwater System" - both pumps were verified oper-a.
able.
In addition, the licensee initiated an internal corrective action process when RPM on the steam-driven auxiliary feed pump was outside of the licensee's administrative limits.
b.
MC-11 " Safeguards Boron Sample" MO-20 " Inservice Test Procedure - Charging Pumps" c.
d.
MI-1 "NT Power Range, Rod Drop Alarm Flux T Calibration System" No items of noncompliance or deviations were identified.
5.
Maintenance Selected station maintenance activities were reviewed to ascertain compliance to Technical Specifications, procedures, and industry codes and standards, as appropriate. The review considered personnel quali-fications, procedures, removal from and return to service, approvals, reviews, and documentation. The following completed Maintenance order packages were reviewed: a.
MO 81-FWS-071 through -073: calibration of new pressure transmitters and switches in AFW pump suction b.
MO 82-FWS-0061: removal of old mechanical pressure switches in AFW pump suction
< . e c.
82-PCS-0018: replacement of instrumentation flange studs.
d.
82-FHS-0020: replacement of a refueling machine spreader o.
82-ESS-139: changeout of the personnel air lock gasket seal f.
82-ESS-118: replacement of valve MV-3420 g.
82-CVC-75: replaced a circuit card in the boric acid heat tracing system.
h.
82-CVC 146 and 147: replacement of a circuit in the boric acid neat tracing system No items of noncompliance or deviations were identified.
6.
Licensee Event Report Followup 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 recurrenca had been accomplished in accordance with Technical Specifications.
a.
(Closed) LER-80-40 " Unplanned Airborne Release." While sluicing resins from the spent fuel pool demineralizer to the spent resin storage tank, an unplanned release of fission gas occurred through a relief valve to a monitored path when service air overpressurized the system through a leaking supply valve. The licensee identifi'ed and repaired several pieces of inoperable equipment and made numerous procedure changes. The licenses calculations were verified in a previous report.1 b.
(Closed) LER 82-18 " Boric Acid Heat Tracing Failure." During power operation, a circuit card for one channel of boric acid heat tracing failed. The card was replaced and the channel was returned to service within the time limit of the Technical Specifications.
c.
(Closed) LER 82-21 " Hydraulic Snubber Failure." One snubber, without visual oil level, was identified during routine surveillance. The snubber was replaced and returned to service within the time limit of the Technical Specification.
d.
(Closed) LER 82-28 " Boric Acid Heat Tracing Failure." During power operation a heat trace circuit for the boric acid gravity feed line to the charging pumps failed. Subsequent to replacement of the circuit, a flow test was satisfactorily performed to verify oper-ability of the boric acid gravity feed line. The circuit was re-placed within the time limit of the Technical Specification; cause of the circuit failure could not be determined.
- IE Inspection Report No. 50-255/81-27(DETP)
. . (Closed) LER 82-22 " Incorrect Valve in the Low Pressure Safety e.
Injection System." The licensee discovered, during inspection of , the Low Pressure Safety Injection System, a 3/4 inch, 200 psi, threaded, bronze valve installed at test tap MV-3420. Specification required a 600 psi, stainless steel, socket walded valve. The bronze valve was replaced with a socket welded stainless steel valve which was tested and returned to service. The licensee suspects the bronze valve was installed during the 1976 surveillance program.
Analysis established that failure of the bronze valve would not have rendered the system inoperable. A licensee walkdown of the Auxiliary Feedwater System and Engineered Safeguard System verified no other incorrect valves were installed.
The components involved in the valve replacement job, performed per Maintenance Order 82-ESS-118, included a coupling, a spool piece, the valve, another spool piece, and a cap. A review of the Maintenance Order revealed two documentation deficiencies.
(1) The maintenance order required the use of a Repair Inspection Checklist (RIC). The RIC is used to document welding activities on safety related components. The RIC required that the Coupling and two spool pieces be Type 304 sE$inless Steel. A review of the receipt inspection documentation identified that the coupling and spool pieces installed were type 316 Stainless Steel. This item was discussed with the Maintenance Superintendent and Main-tenance Engineer. Preliminary evaluation determined that 316, Stainless Steel is an acceptable substitute.
Palisades Plant Procedure MSM-M-10, " Control of Welding", requires that safety-related welding procedures be implemented including the joining of the correct materials specified by the RIC. Ad-herence to maintenance procedures is a requirement of Palisades Technical Specification 6.8.1.a by reference to Regulatory Guide 1.33, Apprendix A.
Failure to adhere to the requirements of the RIC is a violation of the above Technical Specification (50-255/82-28-02).
(2) The Record of Welded Repair and Alteration was reviewed and , found inaccurate. The Record of Welded Repair and Alteration
was incomplete in that it did not identify all of the weld procedures used, incorrectly identified the material installed, and did not provide an up-to-date sketch of the repair on the back of the form.
It appears that the Record of Welded Repair and Alteration was prepared when the job was planned but never ' updated when problems required modification of the repair. This item was discussed with the Maintenance Engineer and the Main-tenance Superintendent.
Attached to the Maintenance Order was a copy of Specification / Field Change (SFC) 82-136.
This SFC modified the coupling and verified by an attached safety evaluation that the modification does not violate design specifications. The safety evaluation .
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initially specified Type 304 Stainless Steel fer the coupling but, at some time after approval of the safety evaluation, a person made a pen and ink change to specify Type 316 Stainless Steel. The pen and ink change did not document e.oncurrence of the preparer and reviewer of the safety evaluation.
Palisades Plant Administrative Section 9.3, " Safety Evaluation" at para-graph 5.8 states that if a modification is changed such that the approved safety evaluation is inadequate or deficient, a new safety evaluation will be prepared and subject to the original evaluation. Paragraph 5.7 states that a safety evalua-tion has no review and approval requirements because in all cases it is attached to other documents which receive various reviews.
It is not clear that changing Type 304 Stainless Steel to Type 316 Stainless Steel would require a new safety evalua-tion, but it appears that the change justifies documented con-currence of the preparer and the reviewer. This was discussed at the exit interview and with the Technical Engineer subsequent to the exit interview.
The licensee iniated a Deviation Report (DR) to address a apparent departure from the intent of the Administrative Procedures. The licensee also agreed to consider this matter in the next revision to the Administrative Procedures which was in progress at the time of the inspection.
One item of noncompliance and no deviations were identified in this area.
7.
Cold Weather Preparations This inspection included a review of licensee activities to prepare for effects of cold weather. This issue was previously addressed in IE Bulletin 79-24, to which the licensee's response dated October 31, 1979, has been examined in an earlier inspection.2 The licensee has continued to experience no problems with freezing of important components during periods of servere cold weather.
The licensee has prepared guidelines (in checklist form) to assure important plant components are protected from freezing. These guidelines specifically include checks of heaters for outdoor storage tanks and for numerous equipment sp.ces such as valve pits or safety-related pump rooms.
Caustic and water line freeze protection electrical breakers are verified operable, as are associated heat tracing circuits.
Some preventive maintenance activities, such as cooling tower fan oil change, are scheduled and oriented to cold weather protection. Dedicated staff are assigned to monitor cooling tower icing conditions to prevent excessive ice buildup.
No items of noncompliance or deviations were identified.
- IE Inspection Report No. 50-2;3/82-02.
. . 8.
Desir, Changes and Modifications The inspector reviewed completed documentation for the modifications and specification / field changes identified below to verify they were in accordance with 10 CFR 50.59; they were reviewed according to Technical Specifications and the Q.A. program; they were performed to written procedures incorporating appropriate standards; they were properly tested and performance verified; and appropriate changes in related procedures and drawings were made.
a.
FC 510-4 This modification involved relocation of a 1/2 inch control air isolation valve for CV-3006, to a low-dose area. The inspector noted an incorrect basis (not affecting the conclusion) had been given for part of the Safety Evaluation, in that the components in-volved in this FC are addressed in Technical Specifications, contrary to a Safety Evaluation statement. This was noted at the Management Interview.
b.
FC 493 This modification upgraded the auxiliary feedwater pumps low suction pressure trip system, replacing mechanical pressure switches with pressure transmitters, electrical switches, and associated electric components. Related to this modification was conversion of valve 709FW from an instrument isolation valve to a vent valve when the old instruments were removed. This was accomplished, however, by use of a Maintenance Order (supplemental to the Facility Change) some five months after the new system was turned over to Operations.
As a consequence, the Operations Department was not adequately noti-fled concerning this aspect of the modification. This apparently contributed to the subsequent inaccuracy of CL 12.5 concerning valve 709 FW as addressed in Paragraph 3 above.
This was discussed at the Management Interview.
c.
FC-491 This modification involved installation of new, wide range containment water level copitoring instrumentation. The inspector noted minor weaknesses in he Safety Evaluation basis for one section, including an apparent mis-statement of the conclusion. This was dis-cussed at the Management Interview.
d.
FC 510-3 This modification was not performed. The intention was to relocate nitrogen and hydrogen supply isolation valves for the volume control tank, to a low dose area.
It was learned that valves in a low dose area were already the routine control method.
Followup by the inspector identified a valve in each line which is unnumbered, not tagged, and not addressed in related procedures - a condition identified by the licensee nearly a year earlier.
Further review established the valves in question are not " safety-related", so regulatory action was not appropriate, but the matter was discussed at the Management Interview.
e.
Specification / Field Change (SFC) - 82-132.
Allowed use of shims and sealing compound to seal the inner door gasket of the personnel air lock.
. . f.
SFC-82-133 Installed mounting plates behind 3TV8 items 13 through 16 for the States Company terminal blocks.
g.
SFC-82-028 Installed a sump pump in the auxiliary feedwater pump room h.
SFC-82-019 Installed stand pipes for the diesel generator room
floor drains 1.
SFC-82-013 Modified the refueling machine spreader J.
SFC-82-130 Replaced the instrument flange stud bolts k.
SFC-82-136 See Section 5 (LER-82-22) for a discussion of the SFC No items of noncompliance or deviations were identified.
9.
Implementation, Audit Program I An inspection was conducted by a regional specialist on November 1 and i 2, 1982, at the site and on November 22 and 23, 1982, at the corporate office in Jackson, Michigan. The inspection included the following areas of review: audit planning and frequency; training and qualifications of auditors and lead auditors; scope of audits; content of audit reports; response to audit findings by the audited organization; Audit Programs Section staffing and adequacy of procedures.
l The following documentation was reviewed: Audit Reports: A-QA-81-07 A-QA-82-01 A-QA-82-07 A-QA-82-08 A-QT-82-10 A-QA-82-18 l tuditor qualification records Deviation Reports
No items of noncompliance or deviations were identifi-d.
The QA audit scheduling was well organized and showed significant improvement over the previous inspection. The size of the QA audit section had increased from 2 to 8 auditors, which significantly reduced the dependence on contracted auditors.
QA Department Procedures (QADP) XVIII-1 and XVIII-4 were being revised to reflect administrative improvements in the program. Revision 6 to QADP XVIII-1 did not include, for planning purposes, all annual audits i required by Technical Specifications. However, the draft revision to that procedure provided adequate guidance for planning of all audits.
> . This item will remain unresolved until the draft revision to QADP XVIII-1 ' is issued and found to be acceptable by NRC (50-255/82-28-03).
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+ QADP XVIII-4, revision 3, paragraph 5.5 requires " regular and active" participation in the audit program as a condition for auditor requali-fication, but no general guidance is given to define what constitutes " regular and active" participation The same paragraph also requires a an annual review of certification and records of auditor qualifications by the Audit Program Coordinator. This had been done for CPCo auditors; however, one example was found of a contract auditor whose qualification records were not revirwed annually by his parent company. This was apparently an isolated example, and there were no plans to renew the contract due to the increase in the CPCo audit staff size. The inspector recommended that QADP XVIII-4 be revised to assure ths same level of qualifications review for both CPCo and contracted auditors. The licensee agreed to consider these two items in their next procedure revision, which is in draft form. This item will remain unresolved until QADP XVIII-4 is revised and found to be acceptable by NRC (50-255/82-28-04).
10.
Miscellaneous Inspection a.
On November 23, 1982, the inspector participated in the colletion and splitting of a liquid waste sample under the Confirmatory Mea-surements program. Results of comparative analyses on this sample will be addressed in a future inspection report.
b.
The inspector collected and provided assorted documentation for review by an NRC Region III construction specialist. These reviews will result in closcout of selected items under a separate inspection report.' l c.
The inspector and selected Region Ill personnel received, reviewed, and returned to the licenree a copy of a consultant's report prepared and submitted pursuant to a requirement of an NRC Order dated March 9, . 1981. This aspect of the subject Order is considered closed.
i ' 11.
Unresolved Items Unresloved Items are matters about which more information is required in order to ascertain whether they are acceptable items, Items of Noncom-pliance, or Deviations. Unresolved Item (s) disclosed during the inspection is discussed in Paragraph 9.
l 12.
Management Interview A management interview (attended as indicated in Paragraph 1) was conducted , ( following completion of the inspection on December 3, 1982. The following ' matters were discussed: a.
The inspector identified the scope of the inspection as documented in the " Details".
IE Inspection Report No. 50-255/82-27(DETP) l l
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b.
The two apparent items of.cncompliance were specifically identified-and discussed (Paragraph 3 and Paragraph 6.e), c.
Documentation discrepancies not resulting in noncompliance, identified in review of corrective action for LER 82-22, were discussed (Para-i graph 6.e).
The licensee initiated a DR, and will consider means to resolve these discrepancies in a revision to their Administrative Procedures which is in progress.
d.
Documentation weaknesses identified in review of plant modifications were noted, the inspector expressing concern the licensee had over-looked weaknesses in two Safety Evaluations, had not identified incorrect statements, and had not followed up on known minor defici-i encies The licensee agreed to examine the specific instances as j discussed in Paragraph 8 of this report.
, e.
The inspector identified matters to be closed on the basis of review by a Region III construction specialist and advised the licensee the review resulted in no regulatory findings (Paragraph 10.b).
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