IR 05000255/1986024
| ML18052A695 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/17/1986 |
| From: | Darrin Butler, Hare S, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052A694 | List: |
| References | |
| 50-255-86-24, NUDOCS 8609230165 | |
| Download: ML18052A695 (10) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/86024(DRS)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Covert, MI License No. DPR-20 Inspection Conducted:
August 11-14, 20-21, and 25-27, 1986 0~4 fJv+/-A Inspectors:
David S. Butler Approved Steven M. Hare By:~~Chief Operational Programs Section Inspection Summary Inspection on August 11-14, 20-21, and 25-27, 1986 (Report No. 50-255/86024(DRS))
Areas Inspected:
Routine, announced inspection of actions taken on previously-identified items (IE Module 92701), the effectiveness of licensed operator training (IE Module 41701) and the effectiveness of non-licensed staff training (IE Module 41400).
Results:
Of the three areas inspected, no violations or deviations were i dent i fi ed.
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8609230165 860918 PDR ADOCK 05000255 G
- DETAILS Persons Contacted
- J. S. Rang, Director, Nuclear Training 0 R. A. French, Superintendent, Operations 0 *W. G. Merwin, Training Administrator R. B. Heimsath, Supervisory Instructor II P. D. Rigozzi, Supervisory Instructor I R. D. Orosz, Manager, Engineering/Maintenance 0 R. J. Frigo, Supervisor, Operations Staff Support
°K. E. Osborne, Technical Engineer 0 D. G. Malone, Licensing, Senior Engineer
- Denotes those in attendance at the exit meeting on August 21, 1986.
0 Denotes those in attendance at the exit meeting on August 27, 1986.
The inspectors also talked with and interviewed other members of the licensee 1s staff during the course of the inspectio.
Licensee Actions on Previously-Identified Items (92701)
(Closed) Violation No. 255/84027-01:
Nonconservative setting of the four pump low flow trip setpoin Special test procedure T-69, 11 Reactor Protective System - Low Flow Trip Calibration Procedure, 11 was not performe This resulted in Surveillance Procedure MI-2, 11 Reactor Protective Trip Units, 11 not being modified with the correct low flow setpoin Since special test procedures are not scheduled the same way as surveillance tests, the failure to modify the surveillance procedure resulted in missing the modification low flow setpoint The licensee has written Surveillance Procedure RI-94, 11 Reactor Protective System - Low Flow Trip Calibration Procedure.
RI-94 was scheduled to be performed each refueling outage and provided adequate steps to ensure MI-2 was modified with the correct setpoin The setting for three pump low flow operation had been set well above the Palisades Technical Specification (TS) valu This should preclude any three-pump operatio (Open) Open Item No. 255/85003-24(DRP):
No documented training program for the Maintenance/Technical and Administrative Departments existed as required by Palisades administrative procedure The licensee had identified this problem and had committed to developing the required training progra As of the conclusion of this inspection, the licensee was still in the process of developing training programs for these areas; however, insufficient progress had been made to close this ite (Closed) Violation No. 255/85008-03:
Failure to record station battery cell temperature Surveillance Procedure ME-12, 11 Battery Checks,
had been modified to provide adequate instruction to record the cell temperatur This appeared to be an isolated case in not following procedural step The individuals involved were counseled on the importance of procedural adherenc *
(Closed) Violation No. 255/86008-04:
Failure to record station battery electrolyte levels as required by T Procedure ME-12 had been adequately modified to ensure the electrolyte levels were recorde (Closed) Open Item No. 255/85003-06:
Repair/replacement of non Q-Listed Component Cooling Water Low Flow, Engineering Safeguards Recirculation to the Safety Injection-Refueling Water Tank (SIRW), transmitter (FT-0404).
The transmitter flow orifice was located in a common return line from the SI recirculation line and Spent Fuel Pool (SFP) fast recirculation lin The transmitter was over-ranged during normal plant operation by the high flow SFP recirculatio This had caused the transmitter not to function properly when required to measure SI mini-recirculation flo The licensee had issued Facility Change (FC)-69 The flow orifice was to be relocated in the SI recirculation pipin The FC package was complete and scheduled for implementation during the 1988 refueling outag The SIRW tank will be drained during that outag This should provide a safe plant condition to perform the chang (Closed) Open Item No. 255/85003-08:
Clarification of the type, accuracy, and range of measuring and test equipment (MTE) to be used in test procedure The licensee addressed this item in Action Item Record (AIR),
A-PAL~85-50. A comprehensive program was developed and was continuing with the procedure revie Approximately 83% of the procedures have been complete Surveillance Procedures MI-2, RI-3, and RI-5 were verified to have adequate MTE specifie (Closed) Open Item No. 255/85003-09:
Include MTE inaccuracies in TS Surveillance Procedure Basis Document (PBD) setpoint calculation The licensee addressed this item in AIR, A-PAL-85-5 The licensee was revising the PBDs and including the MTE inaccuracies in the calculation The PBD for tests MI-2, RI-3, and RI-5 were verified as complete The licensee applied the Root-Sum-Square (RSS) statistical method to each calculatio The maximum loop uncertainty was determined and verified to be within TS limit The licensee did an excellent job in addressing this concer (Closed) Open Item No. 255/85003-10:
Verify the 11 As Left 11 calibration formula is equal to, or better than the 11As Found 11 formula for Data Precision Model 3500 digital multimeter The licensee had clarified what values were substituted in the calibration formula The 11As Left
formula (0.007% RDG + 0.001% FS + 1 Digit) uses 0.1, 1.0, 10.0, 100.0 and 1000.0 Vdc for the full-scale valu The 11As Left 11 formula was equal to the 11As Found 11 formula (0. 007% RDG + 2 Digit).
(Open) Violation No. 255/85003-07:
Calibration of safety-related equipment without a procedur The inspector reviewed the licensee 1s corrective actions addressed in Administrative Procedure 5.04, 11Control of Installed Plant Instrumentation (IPI).
Section 7.1, 11Calibration Procedures, 11 did not delineate between safety-related calibrations and work to be performed as skills of the Repairman/Technicia *
Skills of the Repairman/Technician are described in Procedure 5.01, 11 Processing Work Requests/Work Orders;* and NODS-P12, 11 Nuclear Operating Plants Maintenance Program.
The items in question were:
Procedure NODS-P12 Adjustment and repair of pneumatic relays, booster relays and pi 1 ot Minor adjustments to transmitters (i.e., adjusting zero). Troubleshooting, repair, and calibration of pneumatic and electronic recorder Installation, maintenance, and adjustment of pressure gauges and pressure switche Procedure 5.01 Electrical adjustment same as i. abov same as j. abov same as k. abov same as m. abov Procedure NODS-P12 further details in Section 5.1, 11Maintenance Procedures, 11 that maintenance of safety-related structures, systems, or components shall be preplanned and performed in accordance with written procedures, documented instructions, or drawing NODS-Pl2, Section 5.1, appeared to be in compliance with Consumers Power Company-2A quality assurance document Section 5.0, 11 Instructions, Procedures and Drawings
- except, there was no mention of procedural controls for activities affecting the quality of safety-related structures, systems, and components that would include acceptance criteria for determining if an activity had been satisfactorily complete Acceptance criteria have to be established to determine if an adjustment/
calibration has been satisfactorily complete When an adjustment is performed, a comparison usually has been made with a working standard (measuring and test equipment), whether it is a ruler, gage block or electronic measuring devic The licensee needs to clarify how they will control and perform adjustments/calibration on safety-related equipment as described in CPC-2A, Section Further review of Procedure 5.04 raised additional concerns: The Instrument Calibration Data Sheet provides adequate controls for returning to service components connected to process fluid There is no mention on how to control lifted leads and positioning of slide link The landing of wires and final positioning of slide links is part of the restoration proces The licensee needs to provide adequate controls to ensure that total restoration of equipment is completed and verifie *
- Section 7.4, 11Calibration Practice, 11 describes how to verify loop operation following restoratio No instructions are provided on how to crosscheck between channels that read zero during normal plant operatio The licensee needs to clarify how they will perform this type of loop operability verificatio.
Training The inspection consisted of a review of deviation/event reports which occurred during the years 1984 through 1986, to determine if sufficient training could have prevented the event or mitigated its effec The inspection was not designed to be an evaluation of the licensee's overall training progra That evaluation is currently performed by the Institute for Nuclear Power Operations (INPO) as part of the training accreditation proces At the time of this inspection, five of the training programs had been accredite These were as follows:
(1) Non-licensed Operator; (2) Licensed Operator; (3) Licensed Operator Requalification; (4) Shift Technical Advisor; and (5) Instrument and Control Technicia The five remaining programs had been formally submitted for accreditatio These were as follows:
(6) Electrical Maintenance; (7) Mechanical Maintenance; (8) Radiation Protection; (9) Chemistry; and (10) Technical personne Full accreditation was expected by mid-198 Licensed Operator Training Effectiveness (41701)
The inspector reviewed operational events, and interviewed plant personnel to evaluate the effectiveness of training programs for licensed personne In addition, the inspector also reviewed the licensee's interpretation of the operator requalification program 11annual 11 training requirement and informed them of the NRC's interpretatio Deviation and Event Report Review Of approximately 350 DRs and ERs reviewed, the inspectors chose five reports for further review as listed below:
Deviation/Event Report Numbers E-PAL-84-080 D-PAL-86-089 E-PAL-86-049 E-PAL-85-065 D-QP-84-073
Description Procedure violation during initial approach to criticalit Less than 50° ~T between pressurizer and loop Tave limit of Standing Order No. 40 exceede No SROs in the control room with the plant at powe Housekeeping tours by Shift Supervisors not documented on NODS Form 3157
- The reports were discussed with on-shift ROs and SRO Each person interviewed was knowledgeable on the above report Reports84-073, 85-065, and 86-049 were reviewed in requalification trainin Reports84-080, and 86-089 were reviewed during simulator trainin In each case, the individual felt the training was adequat Operator Training The licensee's training program provided several means of disseminat-ing information on recent events to licensed operator These were as follows:
reading daily orders, routing books, memos, shift meetings, and formal trainin Information given out during shift meetings only required the SRO's signatur There was no policy in place to ensure that shift members returning from vacation or illness would receive the information given out during shift meeting The routing book was used for long-term reading requirement Each individual was required to initial/date when the reading was complete The signature sheet had an issue date and due dat The Training Shift Supervisor (TSS) signed/dated the completed readin Two sheets reviewed averaged six months past the due date for completio Memos were issued to individuals on items of immediate importanc The TSS reviewed all pertinent information and may recommend inclusion of materials into formal lesson plan Notification of plant modifications went directly to the TS Training instructors would incorporate the modification in the requalification program, if needed, or present the material directly to personnel on-shif The licensee's formal training program for all operations personnel had been accredited by INPO, and, as such, included the basis of task analysi Instructors appeared to be well qualified, and were required to stand one operations watch per mont The licensee provided the following statistics regarding their license requalification examination results for operators:
License Type Year Number of Exams Given
% Passed SRO 1984
100 RO 1984
50 Instructor Cer SRO 1985
85 RO 1985
50 Instructor Cer Regarding these examinations, the operators interviewed indicated that some of the exam questions were confusin The questions did not contain terms specific to Palisade Discussions with the training department determined that the exams were written and administered by a contracto The exam was first reviewed by the training department while it was administered to the requalification candidate Inspector discussions with Region III NRC examination
- staff determined that there is no requirement preventing the licensee training staff from reviewing an in-house or contractor-prepared requalification exam so long as the integrity of the exam is maintaine Review of the exam just prior to its administration and clarification of 11 non-Palisades 11 terms may improve the quality of tnese examination The training records of several licensed operators were reviewe The records were found to be in orde The most recent performance evaluation was maintained in the training departmen The NRC Form 398 accurately reflected the training received, experience, and time spent on-shift for the individual NRC Interpretation of 11Annual
The Office of Nuclear Reactor Regulation (NRR) reviewed the term, 11annual 11 as it applies to the licensee 1s operator requalification progra The use of the term 11annual 11 had been applied differently for requalification program written exams and reactivity control manipulation The NRR staff accepts requalification programs with annual written exams that are conducted on a 12-month interva Extending the interval between written exams to greater than.12 months would require specific authorization by the Commission pursuant to 10 CFR 50.54(i-1).
This would also apply to the two-year cycle of the requalification program specified in 10 CFR 55, Appendix The NRR staff accepts annual reactivity control manipulations required in NUREG-0737 (Denton letter of March 28, 1980) as completed once within a 12-month perio The licensee 1s interpretation of annual as once within a 12-month period is consistent with this interpretatio Summary The licensee 1s training program was meeting the regulatory bases for an acceptable licensed operator requalification progra The inspector recommends that the following items should be considered for program improvement:
Develop a policy to ensure operators returning to shift have been briefed on information given out during shift meeting *
Develop a policy to complete the 11 routing book 11 reading in a timely manne *
Review contract requalification exams by Palisades management just prior to administering the exam to clarify non-Palisades terminolog * Non-Licensed Staff Training Effectiveness (41400)
The inspector reviewed operational events and interviewed plant personnel to evaluate the effectiveness of training programs for the licensee's non-licensed staf Operational Events The inspectors reviewed approximately 350 Deviation Reports (DR) and Event Reports (ER) to determine whether (1) they were caused by personnel error; (2) the personnel error was caused by deficient training; and (3) if any lessons learned from the event had been factored into the training progra Of these, the inspector chose two events and two deviation reports for further review as listed below:
Deviation/Event Report Number E-PAL-84-029 E-PAL-85-030 D-PAL-84-344 D-PAL-86-045 Description Critical Service Water valve operator disconnecte Failure to follow Battery Surveillanc Failure to follow procedure on returning equipment to servic Incores incorrectly installed in instrumentation flange Event Report E-PAL-84-029 documented the lack of service water cooling to the 1-1 Diesel Generator due to a closed service water valv The valve, CV-0844, would not have opened, if needed, because the declutch pin for securing the air operator or the normal operator to the valve shaft was not installe This situation was caused by an auxiliary operator who, while clearing red tags from the system, removed the declutch pin from the manual operator and did not reinstall the pin to enable air operator actuatio The root cause was identified as lack of familiarity on the part of auxiliary operators in valve declutch pin operation because this particular operation/evolution was seldomly don The corrective action was to instruct the auxiliary operators on fifth shift training week on the proper operation of these actuators and declutch pin This was immediately satisfied by training all operators on-shif No apparent long term training was implemented as a result of this E The inspector interviewed several AO's who had come to work at the plant since the initial training had been performe They indicated that while somewhat aware of declutch pin operation, they were not aware of the previous problems encountered as documented in the ER, and had not been instructed as to the proper operation of this actuator and declutch pi During discussions with training personnel, the inspector was told that a special AO training package was being generated for initial and refresher training that addressed 11 special valves 11 similar to this on The inspector reviewed a draft copy of the preliminary draft AO training package and found it did not reference this valv While the inspector was in the area he noted that the training personnel inserted a section into the AO training package that required the classroom discussion on the operational characteristics of this valv Further investigation revealed that the training department had not received this ER for evaluation and inclusion of the lessons learned into the training progra The inspectors noted that the feedback of this information into the training program was inadequat Event Report PAL 85-030 documented a procedural error where Station Battery Temperature readings taken were not the ones specified in the procedur This item was identified as a violation in NRC Inspection Report No. 255/8500 The inspector discussed this item with selected Electrical Maintenance personnel and found them cognizant of the even The event appeared to be isolated (as documented in the Event Report).
Deviation Report PAL 84-344 addressed an instance where a proper signature had not been obtained on a maintenance order when returning equipment to servic The Root Cause portion of the DR identified a problem with the individuals understanding of the procedur The corrective action portion had the individual read the procedures so as to be clear on the correct action to be take The inspector, through interviews with personnel, could not determine if this was a problem that reflected on the licensee 1 s training progra Deviation Report PAL 86-045 documented an error in the installation of cables for the incore detector Specifically, the cables at four locations had not been installed in the correct flange hole This error was attributed to failure to follow procedure with a contributing factor of poor overhead rigging support While this DR was still being processed, the proposed corrective action was to revise the procedure to increase awareness of proper cable locations and to obtain better rigging to enhance flange removal and reinstallatio The inspector discussed this item with personnel in the responsible departments and found they had been made aware of the proble Personnel Interviews The inspector interviewed personnel from the Operations, Instrumenta-tion and Controls, Mechanical Maintenance and Electrical Maintenance departments regarding the present training program and their perceived weaknesses in that progra,
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The inspector noted a potential problem in the area of Mechanical Maintenanc Currently machinists do not receive a comprehensive training progra Apparently, at the Supervisor's discretion, a machinist should, over a several-year period, receive sufficient training to perform the job effectively. Adequate training for an extended period of time may not be realized because of scheduling difficulties or because of supervisorial discretio The licensee stated they were aware of the potential problem with machinist training and were pursuing a solution to i No other problems were identified during the interview Summary Throughout the inspection the inspectors found it difficult to judge the effectiveness of the licensee's non-licensed training programs because of the changing status in the development and implementation of their INPO actreditable training programs in the area of non-licensed trainin In regard to ER and DR feedback into training, the licensee depended primarily upon the Corrective Action Review Board (CARB) and Plant Review Committee (PRC) review of DRs and ERs to determine if the lessons learned from the reports should be fed back to the training departmen The training department would only see the DRs or ERs if one of these groups identified it as a training proble Because of previously-identified shortcomings in their CARB and PRC review of DRs and ERs, (See IE Inspection Report No. 86008) and the problems discovered by the inspectors with ER PAL 84-029, the licensee's method of feedback should be augmente The inspectors recommended that the training department be on distribution for all DRs and ERs so that they could review them independently to determine if a training problem existed or if
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n~i~n g_il.l_a_s_p_ed_f_i_c_a~ea-cou-1-d-be-impY'oved-. - - Exit Interview The inspector's met with licensee representatives (denoted in Paragraph 1)
on August 21 and at the conclusion of the inspection on August 27, 1986, and summarized the scope and findings of the inspectio The licensee acknowledged the inspector's statement The inspectors discussed the likely informational content of the report with regard to documents reviewed by the inspecto The licensee did not identify any such documents as proprietar