IR 05000255/1985015
| ML20137F714 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/22/1985 |
| From: | Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137F686 | List: |
| References | |
| TASK-2.K.3.05, TASK-TM 50-255-85-15, NUDOCS 8508270060 | |
| Download: ML20137F714 (9) | |
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U.S. NUCLEAR REGULATORY COMISSION
REGION III
m Report No.. 50-255/85015(DRP)
. Docket No. 50-255.
License No. DPR-20 Licensee: LConsumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
June 3 and 4, 1985 June 11 through July 8, 1985 Inspectors:
E. R. Swanson J. M. Ulie J. A. Holmes
. Nigit
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Mn,reer ApprovedBy:[RebctorProjectsSection2A
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. Inspection Summary
' Inspection on June 3, 4, and 11 throuc h July 8,1985 (No. 50-255/85015(DRP))
Areas Inspected:
Routine, unannouncec inspection by resident and regional.
. inspectors of previous inspection findings; operational safety; maintenance; surveillance; engineered safety features walkdown; reportable events; design changes; audit program implementation and independent inspection areas. The inspection involved a total of 163 inspector-hours onsite by three NRC inspectors. including 22 inspector-hours on site during off-shifts.
Results: _0f-the areas inspected no violations, deviations or items of safety concern were identified.
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DETAILS 1.
Persons Contacted J. F. Firlit, General Manager
- J. G. Lewis, Plant Technical Director
- T. Palmisano, Engineering and Maintenance Manager C. E. Axtell, Health Physics Superintendent
- J. R. Schepers, Chemistry Superintendent C. S. Kozup, Plant Operations Superintendent W. M. Hodge, Property Protection Supervisor
- R. A. Fenech, Technical Engineer
- D. L. Fitzgibbon, Licensing Engineer
- R. E. McCaleb, Quality Assurance Director
- Denotes those present at the Management Interview Numerous other members of the plant Operations / Maintenance, Technical, and Chemistry Health Physics staffs, and several members of the contract Security forces, were also contacted briefly.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Open Item (255/83018-03):
Technical Specification 4.17.4 requires a hydrostatic test of the outside fire hoses every three years which is not consistent with 10 CFR 50, Appendix R, Paragraph E which requires an annual hydrostatic test.
The inspectors reviewed the " Palisades Nuclear Plant Fire Protection Implementing Procedures.'
Procedure No. FPIP-5, Revision 3 part 5.5(c) requires an outside
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fire hose surveillance and hydrostatic test annually.
The inspectors were provided with an operation checklist (CL 21.12, Revision 6) entitled " Annual Outside Hose Station Fire Hose Surveillance and Hydrostatic Test" which provides instruction for hydrostatic testing of fire hoses located in the outside fire hose houses.
The procedure is to be issued to the plant shift operations supervisor for authorization and scheduling at the beginning of the calendar month in which the annual hydrcstatic test is due.
b.
-(Closed) Open Item (255/83018-04):
The fire implementing procedures identified eight self contained breathing units available for use.
This was not consistent with 10 CFR 50, Appendix R, which requires ten self contained breathing units.
The inspectors reviewed fire protection implementing procedure FPIP-3, Revision 2, entitled
" Breathing Air Supply" which indicated at least 12 Self Contained Breathing Apparatus (SCBA) are located within the nuclear facility.
In addition, the inspectors obser.ved at least 12 SCBA within the facility.
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c.
(Closed) Open Item (255/83018-05):
10 CFR 50, Appendix R, Paragraph K.5 requires the use of a flame permit to govern flame producing operations; however, fire implementing procedures did not require the use of a flame permit.
The licensee has incorporated a hot work permit system in the Fire Protection Implementing Procedure (FPIP) No. 7, Revision 4.
The hot work permit requires that the job supervisor consider the appropriate safeguards such as combustible materials, fire damage, openings, cleanliness, explosive gases, fire detection / suppression systems, surrounding area combustibles, and the location of the communication equipment.
The hot work permit expires at 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on the Saturday following issuance.
The inspectors requested the licensee to review the hot work permit to ensure that the decision regarding appropriate safeguards are made.by a qualified and experienced individual such as the Plant Property Protection Supervisor.
The inspectors also requested that the licensee review the duration of the work permit and limit the work permit to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as addressed in Section III.K.5 of 10 CFR Part 50, Appendix R.
The licensee indicated that these issues have been reviewed and that it was their conclusion that the present procedure is adequate; however, if, through experience, these practices were found inadequate, the procedures would be updated.
d.
(0 pen) Open Item (255/83018-06):
No defined and documented program for the qualification of contractor personnel to perform as fire watches was apparent. The licensee indicated that the General Employee Training (GET) Program is the type of training received by individuals performing as fire watches on an annual basis.
It is the inspector's concern that the fire watches used for cutting /
welding operations may not be adequately trained to fight a small incipient fire.
The inspector requested that the licensee review the training requirements for fire watch personnel and utilize NFPA 518 " Standard for Fire Prevention in use of cutting and welding processes," which indicates that fire watches be trained in the proper use of extinguishers including practice on test fires.
As discussed in a telephone conversation on June 24, 1985, between Palisades and Region III, the licensee indicated that this issue is currently being reviewed.
This item will remain open pending review of the licensee's action.
No violations or deviations were identified.
3.
Operational Safety a.
The inspector observed control room activities, discussed these activities with plant operators, and reviewed various logs and other operations records throughout the inspection.
Control room indicators and alarms, log sheets, turnover sheets, and equipment
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status boards were routinely checked against operating requirements.
Pump and valve controls were verified proper for applicable plant conditions.
On several occasions, the inspector observed shift turnover activities and shift briefing meetings.
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Tours were conducted in the turbine and auxiliary buildings, and central alarm station to observe work activities and testing in-
progress and to observe plant equipment condition, cleanliness, fire safety, health physics and security measures, and adherence to procedural and regulatory requirements, s
b.
During review of logs and surveillance promedure MC-118, which samples the Safety Injection Tank-(SIT) concentration, a concern was raised as to whether operators were following the procedural-guidance that existed.
MC-11B directed that a sample be taken after flushing the line for four minutes and that the valves were to be closed within six minutes of opening.
Operators were continuing to drain the system using this lineup below the lower Technical Specification limit (LCO) and then refilling to increase the concentration of boron in the tank.
This mode of operation was in anticipation of dilution of the SIT concentration due to inleakage from the primary coolant system.
The inspector's concern was the intentional entering of a LCO without the use of a reviewed and approved procedure.
The licensee committed to revise the appropri-ate procedures (50P-3, MC-118).
This.is an open item (255/85015-01).
c.
Diesel Generator 1-1 was declared inoperable on June 22, 1985, due to leakage from a temporary gage installed in the lubricating oil system.
It had been installed May.26, 1985, to assure that prelube
' oil pressure was_available while the associated pressure switch was operating erratically.
The inspector asked if this was a properly
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controlled and qualified modification.
This is an unresolved item pending a response from the licensee (255/85015-02).
No~ violations or deviations were identified.
4.
Maintenance The inspector reviewed and/or observed the following selected work activities and verified appropriate procedures were in effect controlling removal from and return to service, hold points, verification testing, fire prevention / protection, and cleanliness.
DTA 24503001 Jumper primary rod position indication for rod #31 to-allow alarm of others in group DTA 24503004 Jumper secondary rod position indication for rod #31 to allow alarm of others in group ESS 34502539 Preventive maintenance on P-558 breaker
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CR0 2450130 CRDM seal housing hydro test using procedure CRD-M-31 Step 5.7.11 No violations or deviations were identified.
5.
Surveillance The inspector reviewed surveillance activities to ascertain compliance with scheduling requirements and to verify compliance with requirements relating to procedures, removal from and return to service, personnel qualifications, and documentation.
The following test activities were inspected:
a.
Low Pressure Safety Injection Monthly Test M0-24 b.
Step 5.3.11 of Procedure T-FC564-6640-501 Turbine Driven Auxilia"r Feed Pump Control Test M-378 No violations or deviations were identified.
6.
Engineered Safety Features Walkdown The inspector performed a walkdown of the Containment Spray System and verified:
that each valve in the flowpath was in its required position and operable, that power was aligned for components that activate on an initiation signal, that essential instrumentation was operable, and that no conditions existed which would adversely affect system operation.
An unusual condition noted during the walkdown was desiccant in the filter bowls in air lines to CV 3213 and 3223.
The licensee has had problems with the instrument air dryers experiencing after-filter failure.
The desiccant'has caused valve operating problems and corrective actions taken thus far include filtering the air supply at the inlet to critical valves.
Two other valves, CV 3001 and CV 3002 which are normally closed, isolate the containment spray headers.
These valves did not appear to have filters installed. The licensee is investigating this situation which is considered an open item (255/85015-03).
The 602 foot level pipeway was noted as being the worst radiological and housekeeping area in the plant.
L4eaking systems and radiological control debris make up most of the pr>blem, with one high radiation area being caused by a three Rem /hr pile of dirt.
A plan has been generated for the cleanup of this area with the goal of making the area more readily accessible to plant operators. This cleanup will be monitored on a routine basis by the inspector.
No violations or deviations were identified in this area.
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7.
Licensee Event Reports Through direct observations, discussions with licensee personnel, and review of records, the following reportable event was examined to determine that reportability requirements were met, immediate corrective action was accomplished as appropriate, and corrective action to prevent recurrence has been accomplished per Technical Specification.
(Closed) LER 255/85-006: On May 23, 1985, routine exercising of control rod #31 found that it would not drive in the "out" direction.
Since control rod #24 was already inoperable by virtue of not having been exercised weekly due to seal leakage, Technical Specification 3.10.4.b required a shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Control rod #24 was exercised and declared operable.
Additional attempts to move rod #31 were successful and rod #31 was declared operable.
The cause was considered to be mechanical binding which was overcome by exercising. These actions eliminated the shutdown requirements.
After successful testing on May 30, 1985, control rod #31 again failed to withdraw during the June 6, 1985 testing. Additional troubleshooting determined that the drive motor brake was binding or disengaging improperly.
Final verification of the cause of failure is an open item (255/85015-04).
Disassembly of the rod drive will likely take place during the refueling outage scheduled to start November 30, 1985.
No violations or deviations were identified.
8.
Design Changes e
One design change was reviewed for correct implementation of 10 CFR 50.59 review provisions, procedural controls, review and approval per QA/QC controls, testing, operating procedure changes, operator training, as built drawing changes, and annual reporting of changes done under 10 CFR 50.59 provisions.
Facility Change (FC) 452-2 was implemented to provide continued Component Cooling Water (CCW) to the Primary Coolant Pumps (PCP) after a Safety Injection Sequence actuation signal.
This change allows for continued operation of the PCPs as outlined in the licensee's response to TMI item II.K.3.5 by adding a relay in the containment isolation logic for CCW which would actuate on low CCW discharge pressure.
In this logic, an actuation of SIS would permit forced cooling of the core during a small break loss of coolant accida nt and reduce the probability of the pump seals becoming a leak path. A break in the CCW piping would be indicated by a loss of CCW pressure and make up the remaining logic to isolate the CCW piping from containment.
Since the added relay in series with the SIS relay is now required under conditions necessitating isolation of CCW from containment, this change is potentially an unreviewed safety question by having increased the probability of malfunction of equipment important to safety.
In addition it was determined that quality requirements for the parts used were not specified by purchase order documents as required by ANSI NI8.7-1976
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Section 5.2.13 and ANSI N45.2.13-1976.
The actual qualification of the parts used is not yet known.
Design engineers incorrectly determined that the IEEE 323-1974 definition of safety class lE was not applicable to these components.
Class IE includes "the electric equipment and systems that are essential to... containment isolation, or otherwise are essential in preventing significant release of radioactive material to the environment." Further, the original design utilized diverse and redundant SIS signals to actuate the CCW isolation valves, while the modification utilized a single pressure switch and relay to meet the logic requirements of the two trains.
Design verification required by Section 6 of ANSI N45.2.11-1974 appeared ineffective and less rigorous than that required by the standard.
Section 8 of the same standard requires that the organization designated to review and approve design changes ".. shall have access to pertinent background information, have demonstrated competence in the specific design area of interest and have an adequate understanding of the requirements and intent of the original design." It was not apparent from the documentation package that the reviews were conducted by the appropriate organization especially since the design change appears to have degraded the containment isolations system quality.
The above issues are unresolved pending further research by the licensee (255/85015-05).
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No violations or deviations were identified.
9.
Audit Program Implementation The inspector reviewed the completed audits of the maintenance area (QT-85-7) and fire protection (QT-83-23) and verified:
that the scope and results of the audit were defined, that personnel conducting the audit were qualified and independent of the audited organization, that action was initiated on the audit findings, and that responses were generally timely and appropriate for identified deficiencies.
Schedules and several completed audits were also reviewed to verify that the audits were performed in accordance with the schedule and program requirements.
Concerns discussed with the licensee included the procedural requirements for documentation of Technical Specialist briefings and use of the
" finding" and " observation" classifications for deviations from QA program requirements.
The violation concerning the use of these classi-fications identified in report 255/85003 (item 2) was discussed but not closed.
No violations or deviations were identified.
10.
Independent Inspection Activities a.
The inspector observed radiological safety practices in the radiation controlled areas including: verification of proper posting; accuracy and currentness of area status sheets; verification of selected Radiation Work Permit (RWP) compliance; and implementation of proper personnel survey (frisking) and
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contamination control (step-off pad) practices. Health Physics logs and dose records were routinely reviewed.
b.
The inspector observed physical security activities at various access control points, including proper personnel identification-and search; and toured security barriers to verify maintenance of integrity. Access control activities for vehicles and packages were occasionally observed. Activities in the Central Alarm Station were observed.
c.
An ongoing review.of all licensee corrective action program items at the Event Report level was performed.
d.
The licensee's Fire Protection Implementing Procedure (FPIP)
Section 3, Revision 0, Paragraph 5.1.2 dated August 31, 1982, required a minimum of three members of the Plant Fire Brigade to be Operations Personnel. The licensee's use of this wording met the technical requirements of Section III.H of 10 CFR Part 50, Appendix R; however, in Revision 2 of the FPIP, Section 3, Paragraph 5.2.1, th'e licensee indicated that the five person fire
. brigade would be composed of both Plant Operations and Security personnel. The Senior Resident Inspector, after discussions with the Regional Fire Protection Inspector, raised a concern to the licensee regarding the present procedure wording which would allow a Fire Brigade to consist of one Auxiliary Operator as Brigade Leader and four security personnel who do not regularly receive plant system training or routinely perform plant system duties.
The licensee's staff indicated that the change to the wording in the procedure was based on the licensee's recognition that there would be a limited availability of Operations Personnel during such events as a shutdown from outside the control room which involve numerous operator actions.
The licensee indicated it was still their intention to man the fire brigade _predominantly with operations personnel.under all other circumstances. The licensee's fire brigade composition as written in Revision 2 to Section 3 of the procedure is in accordance with previously approved NRC requirements.
The inspector determined that the licensee is not committed to the fire l
brigade composition specified in Section III.H of Appendix R, and as such, their position is acceptable.
e.
An Unusual Event was declared at 1718 hours0.0199 days <br />0.477 hours <br />0.00284 weeks <br />6.53699e-4 months <br /> on June 21, 1985, when two Emergency Core Cooling System components were inoperable at the same time requiring that the unit be placed in hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Technical Specification 3.3).
The "D" Safety Injection (SI) tank was below the minimum required level and was being filled by the High Pressure Safety Injection (HPSI) pump when the HPSI discharge valve would not stay open. The failure of this valve (M0-3062) rendered the HPSI flow path inoperable since it is designed to automatically open on a SI signal.
By using an alternate fill path the operators refilled the SI tank and declared it operable at 1733 hours0.0201 days <br />0.481 hours <br />0.00287 weeks <br />6.594065e-4 months <br />.
Boron concentration of the SI tank was
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at all times greater than the lower limit of 1720 ppm.
After repair and testing the HPSI valve was declared operable at 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> on June 22, 1985.
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No violations or deviations were identified.
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Unresolved Items voresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations.
Unresolved items disclosed during the inspection are discussed in Paragraphs 3c and 8.
12.
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 3b, 6, and 7.
13. Management Interview A management interview (attended as indicated in Paragraph 1) was conducted on March 11, 1985, following the inspection.
The following were discussed:
a.
The licensee agreed to revise procedures associated with adjustment of the Safety Injection Tank concentration (Paragraph 3b.).
b.
Design change controls and the problems identified in Paragraph 8 were discussed.
c.
Other observations, open items and unresolved items contained in this report were discussed and acknowledged by the licensee.
d.
The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not
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identify any such documents / processes as proprietary.
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