IR 05000255/1985023
| ML20205G253 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/29/1985 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205G222 | List: |
| References | |
| 50-255-85-23, NUDOCS 8511130188 | |
| Download: ML20205G253 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
LReport No.-50-255/85023(DRP)
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
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' Inspection At: -Palisades Site, Covert, MI Inspection Conducted: September 11 through October 15, 1985
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Inspector:
E. R. Swanson C.' D. Anderson Ed Approved By:
C. W. Hehl, Chief
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Reactor Projects Section 2A Date /
-Inspection Summary
Inspection on September 11 through October 15, 1985 (Report No. 50-255/85023(D'RP))
' Areas Inspected:
Enforcement Conference and routine, unannounced inspection
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by resident inspectors of action on previous inspection findings; operational
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safety;1 maintenance; surveillance and reportable evonts.
The inspection involved a total of 161 inspector-hours onsite by two NRC inspectors including 28 inspector-hours onsite during off-shifts.
Results: Of the areas inspected two violations were identified relating to missed required surveillance tests and the licensee's corrective actions.
Concerns related to use of procedures and planning for maintenance activities were raised.
The inspection also identified that the licensee's system for-
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granting approval for overtime needs strengthening.
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DETAILS 1.
Persons Contacted Consumers Power Company (CPCo)
- R. B. DeWitt, Vice President, Nuclear Operations
- J. F. Firlitt, General Manager, Palisades
- J. G. Lewis, Plant Technical Director
- K. W. Berry, Director, Nuclear Licensing
- R. D. Orosz, Engineering and Maintenance Manager
.W. L. Beckman, Radiological Services * iager R. M. Rice, Plant Operations Manager C. S. Kozup, Plant Operations Superintendent
- H. M. Esch, Plant Administrative Manager W. M. Hodge, Property Protection Supervisor
- R. A. Fenech, Technical Engineer
- D. L. Fitzgibbon, Licensing Engineer R. A. Vincent, Plant Safety Engineering Administrator R. E. McCaleb, Quality Assurance Director U.S. Nuclear Regulatory Commission (NRC RIII)
- A. B. Davis, Deputy Regional Administrator
- E. G. Greenman, Deputy Director, Division of Reactor Projects
- 8. A. Berson, Regional Counsel
- C. W. Hehl, Chief, Projects Section 2A
- E. R. Swanson, Senior Resident Inspector, Palisades
- W. H. Schultz, Regional Enforcement Coordinator
- J. F. Suermann, Project Inspector
- T. V. Wambach, Project Manager, NRR (Teleconference Only)
- Denotes those present at the Management Interview on October 14, 1985.
- Denotes those present at the Enforcement Conference held on October 2, 1985 in the Region III Office.
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.
Enforcement Conference An enforcement conference was iield at 10:00 a.m. on October 2,1985, at the NRC Region III office in Glen Ellyn, Illinois.
Attendance was as indicated in Paragraph 1.
The purpose of the meeting was to resolve Unresolved Item 255/85018-04. The NRC presented their concerns and potential violations as related to the licensee's August 7, 1985, identification of their failure to perform quarterly testing of five containment isolation check valves.
These concerns were outlined as follows:
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Actions'taken in response to the missed surveillance test did not
follow previous plant practice of declaring the untested components inoperable and then taking the required corrective actions.
Plant Review Committee (PRC) review did not identify that the
planned course of action violated existing administrative procedural controls.
Corrective actions were not initiated in a timely manner (identifi-
cation of missed testing at about 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on August 7, 1985 -
corrective actions commenced at about 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> on August 8, 1985).
Violations of Technical Specification (T.S.) 4.5.2.d(2) existed when
Test Q0-11 " Containment Isolation Check Valve Test" was neither performed as required on January 6, 1985, nor performed quarterly since that time until it was successfully completed on August 9, 1985.
Violation of Technical Specification 6.8.1.c existed when
Administrative Procedure 9.23 " Technical Specifications Surveillance Procedure Implementation and Corrective Action" was not followed.
Following this procedure would have led the licensee to declare the five untested check valves inoperable and commence a shutdown of the reactor under Technical Specification 3.0.3.
Consumer Power Company (CPCo) response to the above items included a detailed review of the sequence of events, discussion of the concerns and violations, and corrective actions.
General comments included:
There was no change in plant practice in that it is still CPCo's
intent to follow proposed Technical Specifications (TS) (not an issue in this case) and consider equipment inoperable for which there is no valid evidence of operability and no TS related Action Statement.
Members of the PRC who convened on August 8, 1985, were aware of the
current practice regarding equipment operability outlined in the administrative procedure.
In fact, a guest member at the PRC had authored the recent procedure change reflecting the plant practice.
The licensee concluded that they had simply forgotten the recent change requirements.
They stated that if they had remembered its existence they would have followed the procedure.
It was not clear to the licensee that the test could be immediately
performed at power without adverse consequences since it involved degrading the containment to perform the test (as documented in a June 2, 1982, letter to the Office of Nuclear Reactor Pegulations)
and the reason for changing the frequency of testing on the schedul-ing document to "during cold shutdown" could not be identified.
Further, the Technical Specification only required the test to be performed quarterly "if practical" or otnarwise during cold shutdown.
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With respect to the violation of the surveillance requirement, the licensee outlined the following corrective actions:
The licensee has completed an in-depth review of the Technical
Specification Surveillance requirements and their associated surveillance tests.
A number of deficiencies were found and are being corrected.
The schedule for Q0-11 has been corrected and a review is ongoing
to review the remaining surveillance schedule for accuracy which is to be completed by November 15, 1985.
The surveillance test schedule has been entered into the computerized
Planned Activity Control Schedule (PACS) which will parallel the manual system during the implementation period.
Improvements in the PACS are planned to provide real time surveillance performance error notification.
Plant surveillances are also now being manually tracked on the plant
daily schedule and forced outage schedule to highlight the surveill-ance requirements.
The administrative procedure which controls the surveillance program
will be changed to require that the appropriate Department Head approve changes to the surveillance scheduling requirements and that this approval be documented.
The Surveillance Program Administrator has been replaced.
- With respect to the administrative procedure violation, the following corrective actions were-outlined:
Administrative Procedure 9.23 was revised to require PRC and Plant
Manager review of an evaluation providing the basis for not considering equipment or components inoperable when the associated surveillance was not performed as required.
Otherwise the equipment or component is to be considered inoperable and the appropriate actions taken.
- Administrative Procedure 9.23 revisions were transmitted to all Shift Supervisors / Shift Engineers and PRC members by October 1, 1985.
To address the broader issue of generally weak plant employee knowledge of foundation documents and administrative controls, the licensee plans to give all Supervisors training on the general requirements of 10 CFR, T.S., FSAR, Quality Assurance documents and Codes and Standards.
This training will be provided by the CPCo Nuclear Operations Training Department, as modified from an existing course, by December 31, 1985.
All employees will receive training on appropriate Administrative Procedures within their respective departments on a schedule targeting completion for June 1986, at which time when the training will be reevaluated.
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The licensee and NRC also ciscussed possible courses of action to resolve problems with the Technical Specifications, and it was decided that the
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licensee would consider converting their custom Technical Specifications to Standard Technical Specifications.
At the conclusion of the meeting, the Deputy Regional Administrator concluded that two violations existed, as set forth in the Appendix to the this report (255/85023-01).
It was also noted that further violations of surveillance testing requirements may result in enforcement action involving civil penalties.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item 255/85013-02(DRP):
No administrative procedure existed limiting overtime as outlined in Generic Letter 82-12. Adninistrative Procedure 1.00 " Plant Organization and Responsibilities" has been changed to include time limitations consistent with the Generic Letter.
This item is considered closed.
(Closed) Open Item 255/85013-07:
Radiation m.vitor 2317 gave a spurious alarm when bumped.
The licensee determined that since the monitor is only required during refueling and since the analyzed fuel handling accident does not assume a concurrent seismic event, there is no need for the monitor to be seismically qualified, though it is considered class IE equipment.
This item is closed.
(Closed) Open Item 255/85013-03(DRP):
The licensee failed to limit the overtime deviation authorization authority to senior management.
Administrative Procedure 1.0, " Plant Organization and Responsibilities",
has been changed to specify that the Plant General Manager or one of his designated alternates (either the Assistant Plant Manager, Plant Engineering and Maintenance Manager, Plant Operations Manager, or Plant Radiological Services Manager (all of whom are senior management)) must authorize deviations.
This item is considered closed.
(Closed) Unresolved Item 255/85005-030:
The licensee does not consider the alarm function of the Saturation Margin Monitor (SMM) to be required for operability of the monitor under Technical Specification 3.17.
The licensee documented their position in a letter to the Office of Nuclear Reactor Regulation (NRR) on June 10, 1985.
Discussions with NRR revealed that the SMM design would likely have been accepted without the described alarm function.
This item is closed.
(Closed) Unresolved Item 255/85008-01:
A discrepancy existed between the date corrective actions were said to have been completed and the date they were documented as complete.
Discussions with the cognizant individual indicated that actions were complete as stated in the letter to the NRC but were documented three months later.
This item is closed.
(Closed) Unresolved Item 255/85018-04:
Two violations were identified as discussed in Paragraph 2 of this report.
This item is closed.
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(Closed) Violation 255/85005-01:
The Safety Injection Tank boron concentration samples taken on February 18, 1985, did not meet the required frequency (approximately seven hours late).
Correction action taken is discussed under Paragraph 8 of this report, LER 255/85-002.
This item is closed.
No violations or deviations were identified during the closecut reviews.
4.
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 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.
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.
The inspector made observations concerning 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 contamina-tion control (step-off pad) practices.
Health Physics logs and dose records were routinely reviewed.
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.
An ongoing review of all licensee corrective action program items at the Event Report level was performed.
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At 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on September 20, 1985, the licensee declared an Unusual Event (UE) due to dense smoke in the vicinity nf the Auxiliary Building elevator.
The fire brigade responded, de-energized the elevator motor and cooled it down with carbon dioxide.
The UE was terminated at 0425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br />.
The fire did not involve any radioactive or contaminated components nor did it inhibit operator access to areas required for plant operation.
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c.
During detailed revicw of surveillance Test R0-11 " Containment High Radiation Isolation Test" on September 30, 1985, it was discovered that not all relay contacts in the left channel were properly verified by the test as required by Technical Specification (T.S.)
Table 4.1.2 item 5d.
After evaluation the licensee declared the circuits inoperable at 1745 hours0.0202 days <br />0.485 hours <br />0.00289 weeks <br />6.639725e-4 months <br />.
Since the Limiting Condition for Operation 3.6 " Containment System" was exceeded, the licensee entered T.S. 3.0.3 which requires a reactor shutdown to the hot standby mode within six hours.
An Unusual Event was declared and the shutdown was initiated at 1845 hours0.0214 days <br />0.513 hours <br />0.00305 weeks <br />7.020225e-4 months <br />.
Technicians verified proper actuation of the untested contacts under the guidance of a Work Order (ESS-24501562).
At 2124 hours0.0246 days <br />0.59 hours <br />0.00351 weeks <br />8.08182e-4 months <br /> the containment high radiation channel was declared operable, the Unusual Event was terminated, and the unit commenced a return to full power from 82.7% reactor power.
d.
On September 17, 1985, the licensee identified that the four pressurizer pressure channels were out of calibration by approxi-mately 30 psi due to an error in the use of the calibration device.
This resulted in non-conservative setpoints for the pressurizer high pressure trips.
The unit was in hot standby and and Unusual Event was declared at 1042 hours0.0121 days <br />0.289 hours <br />0.00172 weeks <br />3.96481e-4 months <br />.
The dead weight tester used for the calibration approximately three weeks earlier had been used with the wrong scale factor for some of the weights resulting in the error found.
One channel had recently been recalibrated due to a drifting
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instrument and when returned to service it was noted that the others (
were uniformly reading lower.
Corrective action included recalibration of the channels which ended
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the Unusual Event.
Additional plans include the addition of an accurate dial gauge to the dead weight tester rig for comparison with the readings obtained from the dead weight tester.
Evaluation by the licensee concluded that although they were in violation of the Technical Specification limits for the settings, a fifty psi safety factor used in the calculation of the high pressure setpoint prevented the error from invalidating the safety analysis.
The above items will receive additional review during closeout of
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Licensee Event Reports.
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No violations or deviations were identified.
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Maintenance The inspector reviewed and/or observed selected work activities and verified appropriate procedures were in effect controlling equipment removal from and return to service, hold points, verification testing, fire prevention / protection, and cleanliness.
Set point changes on radiation monitors (RIA 24504831).
- Check of contacts not tested in test R0-11 (ESS 24501562).
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Installation of EEQ thermostats in the safeguards pump room
(VAS24501226).
During review of the procedure for grouting the holes from the old thermostats it was noted that a pen and ink change had been made to make the procedure compatible with the grout manufacturer's instructions.
Although this case was not significant from a control or safety standpoint, it was suggested that the licensee take action to reinforce the requirements for procedure changes to their engineers.
No violations or deviations were identified.
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Surveillance The inspector reviewed surveillance M0-29 " Engineered Safety Features
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Lineup Verification" to ascertain compliance with scheduling requirements and to verify compliance with requirements relating to procedures, equipment removal from and return to service, personnel qualifications, and docur.lentation.
No violations or deviations were identified.
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Licensee Event Reports Through direct observations, discussions with licensee personnel, and review of records, the following reportable events were 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 255/83-065:
Hanger H214, located on piping between the Safety Injection Refueling Water tank outlet and the safety injection pumps was found overloaded.
The licensee installed a new design support in February 1984, as documented by the licensee's Event Report 83-192.
This LER is considered closed.
(Closed) LER 255/84-007:
During cold shutdown, a power operated relief valve opened several times due to troubleshooting activities on the B Low Temperature Overpressure Protection Channel.
A memorandum dated August 10, 1984, was sent to all department heads discussing the need for more thorough reviews of how maintenance activities may affect plant conditions, components and system and better communications between maintenance, scheduling, and operations personnel.
No additional concerns were identified in this closecut review.
(Closed) LER 255/84-009: While the plant was shut down, a left Safety Injection Signal (SIS) actuation occurred when a technician lifted a lead as directed by an approved but inadequate procedure.
An additional lead was present.on that same terminal.
When the loss of contact between the two leads occurred, the resulting power interruption caused the SIS block relay to drop out allowing a previously present primary coolant system low pretsure signal to initiate the left channel SIS.
A memorandum was
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..y issued August 23, 1984,: describing the event and warning against
" daisy-chained" power supplies both in ^ writing procedures and performing L
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This LER is considered closed.--
(Closed)-LER 255/84-27:. Charging pump breaker closing coils failed for.
each of the two constant speed charging pumps within a two week period.
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. Repairs were made 'within the Technica0 specification time limits.
Inadequate preventive maintenance was determined to be the cause.
' Inspection Report 255/85003(DRP) identified other-preventive maintenance-
' program deficiincies and a violation was hsued in that report. The charging ump breaker's had been. included in'the licensee procedure
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MSE-E-10:p!480 Volt Breaker Inspection and Repair " After evaluation of
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other load centers, load centers 11 and 12 were added to the procedure.
Inspection Report 255/85024()RP) identified that the licensee is not completing the preventive maintenance and contains a violation for failure to.take corrective actions.- These violations will track the remaining concerns identified.in the ' review of this LER.? This LER is closed.
~ (Closed) LER 255/85-002:
Safety Injection T nk (SIT) Surveill.ance performed approximately seven hours late.
Cause was attributed to personnel error and correcthe actions dealt With the individual involved and methods for improving the handling'of issued surveillance.
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- computerized survelilance system has been developed, but needs additional
" refinements before it can aid in detecting and preventing missed surveillances.
The department responsible for the SIT surveillance has made changes which improve the visibility 'of incomplete surveillance
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tests.
This item.is closed.
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No violations.or deviations were identified.
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- ManIdementInterview
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A knagement interview (attenc'ed as indiched in Paragraph 1) was
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scopeandjindingsoftheinspectionwerediscussed.~Theinspector-also discussed t.he'likely informational content of the inspection report with regard.to documents or processes reviewed by the inspector during the inspection. e The;1icensee did not:1dentify any such documents / processes as proprietary.
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