IR 05000255/1986031
| ML20212K768 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/16/1987 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212K751 | List: |
| References | |
| 50-255-86-31, IEB-85-003, IEB-85-3, IEB-86-003, IEB-86-3, IEIN-86-018, IEIN-86-027, IEIN-86-038, IEIN-86-043, IEIN-86-053, IEIN-86-056, IEIN-86-058, IEIN-86-072, IEIN-86-080, IEIN-86-18, IEIN-86-27, IEIN-86-38, IEIN-86-43, IEIN-86-53, IEIN-86-56, IEIN-86-58, IEIN-86-72, IEIN-86-80, NUDOCS 8701290189 | |
| Download: ML20212K768 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-255/86031(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: October 21 through December 8, 1986 Inspectors:
E. R. Swanson C. D. Anderson P. R. Wohld J. K. Heller Approved By:
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////,/g7 Reactor Projects Section 2A D#te Inspection Summary Inspection on October 21-through December 8, 1986 (Report No. 50-255/86031(DRP))
Areas Inspected:
Routine, unannounced inspection by resident inspectors of followup of previous inspection findings; material condition task force items; operational safety; maintenance; surveillance; reportable events; IE Information Notices; IE Bulletins; motor operated valves; and procedures.
Results:
Of the areas inspected no violations were identified. One Unresolved item was identified regarding the use of Temporary Change Notices.
Two open items were identified; one to track a Technical Specification change request submittal to clarify LER 86037 deficiencies, and one to track procedure changes for fire pump surveillance procedures.
8701290189 870121 DR ADOCK 05000255-PDR
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' DETAILS
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1.
Persons Contacted Consumers Power Company (CPCo)
J. F. Firlit, General Manager
- J. G. Lewis, Plant Technical Director
- R. D. Orosz, Engineering and Maintenance Manager W. L. Beckman, Radiological Servicos Manager C. E. Axtell, Health Physics Superintendent R. M. Rice, Plant Operations Manager R. A. Fenech, Plant Operations Superintendent S. C. Cote, Plant Property Protection Supervisor K. E. Osborne, Technical Engineer
- D. G Malone, Licensing Engineer
- R. A. Vincent, Plant Safety Engineering Administrator
- R. E. McCaleb, Quality Assurance Director
- T. J. Palmisano, Plant Projects Superintendent J. D. Alderink, Mechanical Engineering Superintendent
- J. K. Ford, Projects Engineer
- C. S. Kozup, Staff Engineer
- K. A. Toner, Pro.jects Electrical and Instrument and Control Supervisor
- T. C. Bordine, Licensing
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- H. Weiss, B&W, Manager of Technical Support
- 8. V. Van Wagner, ISI Supervisor
- R. W. Doan, Nuclear Operatir.J Experience Review Coordinator NRC Personnel
- B. L. Burgess, Chief, Reactor Projects Section 2A
- P. R. Wohld, Reactor Inspector
- A. T. Howell, Reactor Inspector, Inspection and Enforcement
- R. C. Kazmar, Project Inspector
- C. D. Anderson, Resident Inspector
- E. R. Swanson, Senior Resident Inspector
- Denotes those present at the Management Interview.
- Denotes those present at a Motor-0perated Valve Meeting held in the Region III office in Glen Ellyn, Illinois, on November 17, 1886.
Other members of the Plant Operations, Maintenance, Technical, and Chemistry Health Physics staffs, and several members of the Contract Security Force, were also contacted briefly.
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2.
Followup on Previous Inspection Findings
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a.
(Closed) Violation (255/85018-01): Component Cooling Water containment isolation design did not meet requirements. The modification (FC-657) to correct the design was completed during the current outage.
Training of plant engineers was conducted and consisted of a Seminar on the implementation of IEEE criteria and special training sessions which emphasized the proper use of design documents (checklists) and governing standards.
These training activities were reviewed and several engineers were questioned as to the content and impact of the corrective actions with satisfactory results. The licensee has effectively utilized this instance to improve the knowledge and performance of the site engineering staff.
Overall improvement in the quality of minor modifications has been noted during recent reviews.
b.
(Closed) Open Item (255/85015-03): Desiccant was found in air lines and has caused valve operator problems. The in-line filter to containment spray valves CV-3001 and CV-3002 were identified by the licensee for the inspector.
The licensee has replaced the troublesome air dryers and filter systems to end the problems with desiccant and moisture in the air lines.
Seven blowdown points were added based on past system experience problems.
Blowdown of the air system during the current outage identified significant quantities of desiccant from two points.
The dryness of the desiccant dust indicated proper operation of the new air dryers.
c.
(Closed) Violation (255/85018-02): Safeguards pump room hatches were removed without a Safety Evaluation or administrative controls.
Revision 3 to Administrative Procedure 4.03 " Equipment Control" added the requirement to implement the " Jumper, Link and Bypass" controls of procedure 9.31 for the removal of the Safeguards and Auxiliary Feedwater Pump room hatches.
3.
Follower on Maintenance Task Force Items On May 19, 1986, the reactor tripped from 97 percent power on high primary coolant system pressure following a failure of electro hydraulic system power supplies that resulted in closure of the turbine control valves.
A number of equipment problems, some known prict to the trip, hampered the operators' response to the plant transient.
Subsequent to the plant trip, a Confirmatory Action Letter (CAL) was issued which confirmed that the plant would be taken to cold shutdown and remain shutdown until investigations were conducted of the May 19 reactor trip to confirm the status of safety-related/important to safety, equipment.
In response to the confirmatory action letter the licensee convened an eleven member Material Condition Review Task Force to address the actions required by the confirmatory letter.
The findings of the task force are documented in the Material Condition Task Force Final Report dated July 3, 1986.
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An inspection of selected. items of the Material Condition Task Force
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Report was performed by reviewing the licensee corrective action for the items listed below.
In all cases the status of the item was discussed with the system engineer.
For the items selected, the inspector reviewed work orders,. specification changes, event reports, special test procedures, facility changes, deviation re) orts, and wor < schedules to verify that the item was completed.
For tie items that are complete, but awaiting testing, the inspector verified that the testing was scheduled.
a.
(Closed) Recommendation 2.6.4.3: The followup review by the Plant Safety Engineering (PSE) group should be more detailed and comprehensive to assure that all associated plant problems are appropriately identified.
The inspector discussed this recommenda-tion with the PSE Group Administrator who stated that although the completion of this recommendation was not required prior to startup, it is a goal and is being accom)lished by the education of the PSE group during seminars.
As of t1is inspection report, two seminars have discussed this recommendation.
b.
(Closed)AFW-03: Test the Auxiliary Feedwater Pumps to demonstrate design performance.
The licensee has resolved this item in two phases.
The first phase was to look at pump performance and generate a new pump performance curve using Special Test Procedures T-192, T-187 and T-201 for Auxiliary Feedwater Pumps A, B, and C (respectively).
The inspector reviewed the completed copies of T-192 and T-187.
During this review the inspector identified some inconsistencies in the recorded data.
For example, the readings from two inline pump discharge pressure gauges varied by approximately 1000 pounds.
The inconsistencies were discussed with the system engineer who was able to explain each one.
The inspector noted that the completed procedure should stand alone and not require additional explanation during subsequent reviews.
The procedure was revised to include supporting data.
The second phase was to verify system flow characteristics while the plant is at operating temperature and pressure.
This is done using Special Test Procedure T-202.
The inspector noted that Paragraph 6.2 requires that an Event Report (internal corrective action document) be written if the pump cannot meet its system flow characteristics.
However, the procedure did not address pump operability if flow characteristics are not met.
The inspector suggested that the procedure could be enhanced by addressing the o)erability requirements before the test versus taking a chance tlat an inoperable pump may not be identified in a timely manner.
c.
(Closed) AFW-08: Auxiliary Feedwater Instrument power supplies are common for the flow control valves and low pressure trips to the "A" and "B" Auxiliary Feedwater Pumps.
Several failures of the power supplies due to overvoltage trips have affected operability of the
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"A" and "B" pumps.
The licensee's investigation determined that
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the overvoltage setpoint was set too close to the nominal operating voltage, preventing operational flexibility during non-transient conditions.
In response, the licensee raised the overvoltage setpoint with the justification for the change documented in AFW-08-MAF-02.
The system engineer reviewed the setpoints for the
"C" pump which has a similar design and determined the same setpoint was applicable.
To verify that the overvoltage setpoint does not drift out of specification, periodic and predetermined activity control (PPAC) was written to be completed at each refueling outage.
d.
(Closed) CAS-04: Desiccant and excessive moisture was found in the Instrument Air System.
This problem was initially documented in 1984.
At that time the system did not have a moisture filter before the air dryer and had a filter after the air dryer that was not designed to operate in the temperature range of the dryer.
A moisture pre-filter was installed and the after filter was upgraded consistent with the appropriate temperature range.
In addition, additional blowdown ports were added to the air system at areas that were determined, based on system operating experience, to collect moisture and/or desiccant.
The change out frequency of the filters and desiccant has been established and is controlled by the periodic and predetermined activity control sheets.
The system engineer indicated that desiccant and moisture carry-over has not been a problem since the modifications discussed above were made.
A system blowdown to remove residual desiccant and moisture found no contaminants.
e.
(Closed) FPS-03: Fire Protection System to Service Water System Cross Connect Valve will not open manually against the pressure drop of the two systems.
The licensee has concluded that the valve design was deficient because excessive force was required to open the valve.
The valve design was modified (Specification Change 86-182) by adding a vendor approved torque multiplier.
Testing of the modified design with a partial pressure drop was successful.
Testing with full pressure drop is scheduled prior to startup.
f.
(Closed) PCS-01: Pressurizer Spray Valve (PV-1059) indicated partially closed when a full open signal was applied during the plant trip.
The indicator bracket was found to be rusted and had allowed the indicator to shift.
The bracket was replaced and the indicator recalibrated.
In addition, the valve was disassembled, inspected for foreign material (none found),
reassembled and returned to service.
Although not identified as a problem, similar maintenance activities were performed on the valve and indicator for the other spray line.
Valve stroking and final packing adjustment were performed during hot shutdown.
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_(Closed) PCS-14: Three of the six Target Rock valves for the
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pressurizer and. reactor head vents are known to. leak through.
The six valves were disassembled and inspected for foreign-material.
Small amounts of metal shavings, either left from -
' nitial installation of the vents in 1980 or carry-over from i
reactor coolant pump problems in 1984,' were found in four valves with the greatest concentration in the head vent valves.
Two system flushes and a system hydrostatic test were performed prior to returning the valves to service.
h.
(Closed) ESS-17: Restore the "B" Low Pressure Safety _ Injection-(LPSI) Pump to design flow specifications.
During preoperational testing of the LPSI system (performed in 1970 and 1971), problems with the performance of both LPSI pumps were identified and resolved.
The resolution was to modify each pump impeller, however, these modifications were not reflected in the pump design specifications.
In 1983, the "B" LPSI pump impeller was replaced with an impeller that had not been modified and was incapable of delivering the design flow.
Post maintenance testing failed to identify the reduced flow.
During the current outage the reduced flow was identified and resolved by installing a modified impeller per Work Order No. 24505440 and Specification Change 86-244.
Operation with a LPSI pump incapable of_ delivering design flow was discussed further in Inspection Reports 255/86023(DRP)'and 255/86030(DRP).
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(Closed) MIS-01: Restore the turbine bypass valve to service.
During the May 19,:1986 reactor trip the turbine bypass valve
failed to operate on receipt of a valid signal.
The failure was j
attributed to a stiff actuator spring which prevented operation of the valve. The design and operational history of the valve I
was reviewed and a determination made to replace the valve.
The
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replacement was satisfactorily tested while the plant was in cold F
shutdown.
Testing with the plant at operating temperature and i
pressure was also conducted satisfactorily.
Periodic testing and
. preventive maintenance has been scheduled for the valve.
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-(Closed) CVC-01: Four check valves in the Chemical and Volume
Control System (check valves 2114, 2116, 2154, and 2156) are leaking by their seats.
Check valves 2114 and 2116 are scheduled for
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. replacement during the 1988 refueling outage.
Check valves 2154 and 2156 were repaired and tested with unsatisfactory results. Work Order No. 246065418, for the repair of check' valve 2154 was reviewed.
The inspector found that the body-to-bonnet fasteners
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were reused without requiring / performing a visual inspection for boric acid degradation.
The inspector discussed the industry wide
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problem of degradation of fasteners due to boric acid attack with I.
the Maintenance Superintendent.
The Maintenance Superintendent was aware of the problem and agreed to review the matter.
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After the repairs were determined to be unsatisfactory, check valve
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2154 and 2156 'were successfully replaced per Work Order No. 24606741 and No. 24606739 respectively. Work Order No. 24606741 was reviewed and the paperwork was found to be in order; however, the inspector found that a post-maintenance hydrostatic test was performed using a procedure that had not been reviewed / approved by the plant onsite review committee.
The inspector reviewed the Technical
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Specifications and administrative procedures and was unable to find a requirement for such a review.
The inspector questioned the advisability of using test procedures, the review of which are not addressed in the administrative procedures.
The concerns over fastener inspections and the use of approved hydrostatic test procedures were discussed at the management exit meeting.
k.
(Closed)CVC-06: Intermediate letdown backpressure regulators CV-2012 and CV-2122 were not functioning properly; CV-2012 failed during the May 19, 1986 trip.
The problem was diagnosed as out-of-adjustment actuators and faulty position indicators.
The actuators were adjusted per Work Orders No. 24606308 and No. 24606309. The position indicators were replaced per Specification Change 86-144 and Work
Orders No. 24605794 and No. 24605793.
Specification Change 86-144 and Work Orders No. 24605794 and No. 24605793 were reviewed and no problems were identified.
Functional testing of the control valves
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was conducted at hot shutdown and needed adjustments were made.
1.
(Closed) CVC-13: Three control valves in the Chemical Volume Control System (CV-2153 inlet to blender, CV-2155 outlet to the blender and, CV-2165 primary makeup water to the blender) have not always functioned as designed due to seat leakage.
Replacement of these
valves is scheduled for the next refueling outage.
During this
outage, the seat leakage for each valve was checked and the seat leakage for CV-2155 and CV-2165 determined to be unsatisfactory.
The valves were repaired per Work Order No. 24604819 and No.
2460729. Work Order No. 24604819 was reviewed and the paperwork
appeared to be in order; however the fasteners were reused without
performing a visual inspection.
A previous repair of CV-2165 (Work Order No. 24604724) was reviewed and the inspector found that fasteners were again reused without performing a visual inspection.
Reuse of the fasteners without performing a visual inspection was i
discussed with the Maintenance Superintendent.
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No violations or deviations were identified.
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Opnrational Safety I
The inspectors observed control room activities, discussed these a.
activities with plant operators, and reviewed various logs and other
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operations records throughout the inspection.
Control room s
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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 to be 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 inspectors 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 contamination control (step-off pad) practices.
Health Physics logs and dose records were routinely reviewed.
The inspectors observed physical security activities at various access control points, including proper personnel identification and search, and toured security barriers to verify maintenance of integrity.
Periodic observations were made of access control activities for vehicles and packages.
Observations of activities in the Central Alarm Station were also conducted.
An ongoing review of all licensee corrective action program items at the Event Report level was performed.
b.
While in hot shutdown on November 26, 1986, at 9:20 a.m. during Technical Specification (TS) Test Q0-1, " Safety Injection System Actuation", an Unusual Event was declared when the right channel Design Basis Accident (DBA) Sequencer 34-2 failed to rotate due to mechanical interference.
The safety-related equipment, required to be started by the DBA Sequencer upon a Safety Injection Actuation (SI) with loss of standby power, did not start.
The equipment involved included; the "A" High Pressure SI Pump, two HPSI Motor Operated Valves (M0V), one Low Pressure SI Motor Operated Valve (MOV), a Boric Acid M0V, "A" Charging Pump, "A" Service Water Pump, VIA and V3A Containment Air Cooler Fans and "B" Component Cooling Water Pump.
By a proposed Technical Specification change, the containment cooling equipment is required to be operable for this plant condition.
Not being in compliance with this proposed TS, TS3.0.3wasinvokedrequiringashutdown,thusanUnusualEvent was declared per the licensee s Emergency Plan.
The 10 CFR 50.72 Notification was made at 9:32 p.m.
At 10:19 p.m. a cooldown was initiated.
Urgent maintenance was performed on the sequencer and
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it was determined that a spring retainer on a connecting rod to
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a gear being out of position caused one of the cams to rest upon the spring retainer thereby stoppiryg rotation.
This was readjusted and QO-1 was performed satisfactorily.
The Design Basis Accident Sequencer was declared operable at 10:29 p.m. on the same date, at which time the Unusual Event and cooldown were terminated.
It is noted that this was a repeat event and investigation by the licensee determined that the corrective action to the previous event was incomplete due to management oversight.
Additional preventive maintenance, testing, and long term sequencer replacement are scheduled.
Open Item 255/86014-03 and Material Condition Task Force Item ESS-20 are tracking similar sequencer problems.
No violations or deviations were identified.
5.
Maintenance The inspector reviewed and/or observed the following selected work activities and verified whether ypropriate procedures were in effect controlling removal from and return to servicetesting,fireprevention/ protection,a hold P-8A (AFW) Motor Connection Box Repair (FWS 24607277).
Atmospheric Dump Valve CV-0782 Repacking (MSS 24607613).
Pressurizer Spray Valve CV-1059 Stroking and Packing adjustment (PCS 24608065).
IntermediatePressureControllerPIC-0202, Calibration (CVC 24605245 and 246005120)
Additional Maintenance items were reviewed under the inspection effort documented under Paragraph 2 of this report.
No violations or deviations were identified.
6.
Surveillance The ins)ectors reviewed surveillance activities to ascertain compliance with scleduling 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:
M0-19 Inservice Test Procedure - Containment Spray Pumps (Review only).
T-202 Auxiliary Feedwater P-8A and P-8C System Flow Characteristics (Review only).
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T-214 Testing of Charging Pump P-55A.
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T-216 Service Water Flow Verification.
T-214 Chemical and Volume Control Testing.
MI-2 Reactor Protective Trip Units (Channels A and B).
M0-7B Test of Diesel Firewater Pump P-41 (Review).
SOP-7 Atmospheric Dump Valves Testing.
R0-52 FirewaterPumpTesting(Review).
Surveillance Test R0-52 demonstrates the operability of the three firewater pumps with respect to pump capacity (head and flow) and automatic starting. This test, like M0-78, contains a procedural control error.
Performance data is not taken in the "as found" condition, but instead is taken after the operatc= is directed to adjust the speed of the two diesel driven pumps.
Although the pump performance is measured under standard RPM conditions, the "as found" condition of the pump is not determined.
It was also noted that the two procedures do not refer to their function of supplementing the Service Water System under certain conditions.
The completion of p(0penItemrocedural revisions by the licensee will be tracked as an open item.
255/86031-01(DRP)).
No violations or deviations were identified.
7.
Licensee Event Reports Through direct observations, discussions with licensee personnel, and review of records, the inspectors examined the following reportable events to determine whether:
reportability requirements were met; immediate corrective action was accomplished as appropriate; and corrective action to prevent recurrence has been accomplished per the Technical Specifications.
(0 pen)LER 255/86031: A potential common mode problem was identified concerning excessive vibration and the resultant failure of the ContainmentAirCooler(CAC) system.
Excessive vibration was attributed to the deterioration of the fan motor bearings.
In August 1986, an access cover to the system ducting of CAC 3 was found off rendering the CAC inoperable because of the amount of air drawn by the fan through the opening}bratedoffisindeterminate. bypassing the unit's cooling, coils.
The exact time the access cover v CACs 1 and 4 also had indications ofbearingdeg/86023(DRP), Paragraph 3.j. Additional information can be found radation.
Report No. 255 The root cause of the bearing deterioration is under investigation and a supplemental LER will be submitted with the results.
This LER, in conjunction with LER 255/86024 which describes the No. 2 and No. 3 CAC's inoperability due to throttled servicewaterflow,isbeingtrackedasanUnresolvedItem(255/86023-02(DRP)).
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(Closed) LER 255/86037:
AlicenseequalityAssuranceauditdisclosedtwo
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Radiological Effluent Technical Specifications (RETS) discrepancies.
The high range noble gas monitor, RIA-2327, is not equipped with annunciation capability even though Technical Specification Table 4.24-2, Item 3.d, Footnote (2) states that the annunciation function shall be tested quarterly.
The RETS change request erroneously incorporated the footnote to Item 3.d which was then incorporated in Technical Sperification Amendment No. 85 dated November 9, 1984.
The audit also disclosed that Technical Specification Table 4.24-3 refers to the service wa%r system as having a continuous sampler installed, which it does not.
lhe service water sample actually being obtained by the licensee is a daily, one 1 iter sample from the makeup basin in the proximity of the service water discharge.
The TS does not provide for this compensatory measure.
A continuous sampler is available; however, the installation date has yet to be determined.
The submittal of the TS change request to correct and clarify these discrepancies will be tracked as Open Item 255/86023-02(DRP).
(0 pen) LER 255/86032:
In August 1986, testing of the Component Cooling Water (CCW) System disclosed that the actual CCW flow to the Shutdown CoolingHeatExchanger(SDCHX)andCCWHeatExchanger(CCWHX)isless than the flow values specified in the Palisades FSAR.
The condition has a)parently existed since original plant startup due to undersized CCWHXs w1ich serve to limit the CCW flow to components downstream of the CCWHXs.
Additional information is discussed in Inspection Report 255/86023(DRP),
Paragraph 3.e.
A supplemental LER will be submitted describing the analysis of CCW flow requirements and corrective actions.
This event is being tracked as Unresolved Item 255/86023-03(DRP).
(0 pen)LER 255/86033:
During performance testing in August 1986, Low Pressure Safety Injection (LPSI) pump P-67B did not meet the FSAR requirements of 3000 gpm at 350 feet of head.
The condition has existed since 1983 when a spare impeller was installed in the pump.
Testing following the installation in 1983 was not sufficient to disclose the discrepancy.
Refer to Inspection Report 255/86023(DRP), Paragraph 3.k for additional information.
A supplemental LER will include the impact of the reduced flow on the accident analysis.
This event is being tracked as Unresolved Item 255/86023-05(DRP).
(0 pen) LER 255/86036: TestingoftheServiceWater(SW)Systemin September 1986, disclosed that the performance of the three SW pumps was below the requirements of the Palisades FSAR.
The condition is the result of both an inadequate system design and the installation of replacement impellers which were not modified by the vendor to improve performance, as were the original impellers.
In October 1986, the licensee discovered that the SW temperature had exceeded the temperature of 75 degrees F assumed in the Palisades FSAR on several occasions during 3revious plant operation.
Refer to Inspection Report 255/86027(DRP),
)aragraph 4.b for more information.
During evaluation of the SW system,
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it was determined that without system modifications, anything less than
a full compliment of three SW pumps results in insufficient SW capacity to satisfy design basis loads and is an apparent original plant design deficiency.
A supplemental LER will address the analysis for required SW capacity and corrective actions.
This event is being tracked as Unresolved Item 255/86027-02(DRP).
No violations or deviations were identified.
8.
Information Notices The inspector reviewed selected IE Information Notices (ins) and the licensee's mechanism for determination of applicability, distribution and corrective actions.
The Plant Safety Engineering (PSE) group is assigned responsibility for review of ins for applicability, evaluation for corrective actions and distribution as necessary for information.
If assistance outside of PSE is required, PSE arranges for additional sup) ort through the use of Action Item Records (AIRS).
AIRS are also the meclanism for corrective actions.
The following ins were selected to be representative of various departmental concerns and were reviewed by the inspector for IN program implementation:
IN 86-18 NRC On-scene ResponseDuringaMajorEmergency(Issued March 26, 1986)
IN 86-27 Access Control at Nuclear Facilities (April 21,1986)
IN 86-38 Deficient Operator Action Following Dual Function Valve Failures (May 20,1986)
IN 86-43 Problems with Silver Zeolite Sampling of Airborne Radioiodine (July 10,1986)
IN 86-56 Reliability of Main Steam Safety Valves (July 10,1986)
IN 86-58 Dropped Fuel Assembly (July 11,1986)
IN 86-80 UnitStartupWithDegradedHighPressureSafetyInjection System (September 12,1986)
Additionally IN 86-53 and IN 86-72 are reviewed in more detail below.
PSE has the responsibility to review and initiate action on ins.
The inspector determined that persons are receiving IN: through various informal channels, often on a more timely basis than if PSE decided to route ins to the same individuals.
PSE often routes an IN for informa-tion only with no action specified and appears to determine applicability too narrowly.
For example, IN 86-58, " Dropped Fuel Assembly", was determined not to be applicable by PSE, though the Operations Department
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had incorporated it into the Operators' required reading and the Training
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Department has )lans to incorporate it into their Operations Refueling
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lesson plan.
T1ese two de)artments had received the IN through separate i
channels.
Similarly, at tie time of the inspection, IN 06-80, " Unit Startup With Degraded High Pressure Safety System", had not been evaluated by PSE; however, Training and Operations had incorporated it into their programs.
The established controls for distribution of ins for information and assignuent for action do not appear to be effective or timely.
PSE currently distributes ins to department heads who then determine whom in their department should receive them.
Department heads in receipt of ins may not recognize their responsibility in routing them to appropriate persons raising the concern that applicable information may not be getting to all those affected in a timely manner by the formal process currently in place.
Since the informal mechanisms are not proceduralized, nothing ensures that these mechanisms are adequate er will continue.
Information Notice 85-53 was issued June 26, 1986 to inform power reactor licensees of a potentially generic safety problem involving improper installation of heat shrinkable tubing over electrical splices and terminations.
Licensee Electrical Engineers have recently attended a Raychem workshop where they found that their procedures and practices with respect to installation of the heat shrinkable tubing to be in I
complete agreement with Raychem guidance with the exception of recording the lot number of the material in addition to the kit number in case there was a recall.
Raychem noted that there has never been a recall.
The licensee is confident that all Raychem installations are in
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conformance with the vendor guidance.
No physical inspections have been conducted by the licensee but they are planning to review solenoid valve terminations.
The five month delay between the date of issuance of the IN and the November 1986 assignment for action supports the above
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assertion of untimeliness.
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The ins)ector reviewed a sample of thirty splices and terminations and found t1em all to be in conformance with Raychem installation procedures.
Contractors which installed qualified splices and terminations previously worked under explicit installation instructions and currently work under plant procedures.
There are no open issues regarding Raychem at Palisades.
i Information Notice 86-72 was issued August 19, 1986, to all power reactor facilities to inform licensees of the potential failure of 17-7 PH stainless steel springs in Valcor Engineering Corporation valves due to
hydrogen embrittlement.
Valcor has concluded that hydrogen embrittlement of stainless steel springs is a complex function of high temperature, water chemistry, water flow condition, and time of exposure to the service condition, and has recommended that licensees consider replacing them with Elg11oy springs.
At Palisades in August 1985, a Specification Change was initiated to replace four Valcor sample valves in the Primary Coolant and Low Pressure Safety Injection Systems (SV-1914, 1915, 1916 and 1917) due to both leakage and the desire to make the valves more
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maintainable by changing the end connections.
These valves, which were
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supplied by Sentry Equipment Corporation, were Model V526-5295 and had 17-7 PH stainless steel springs.
During telephone discussions with Valcor on replacement valves, the issue of potential hydrogen embrittlement was addressed; however, the licensee did not receive the 10 CFR 21 Report notification from Valcor.
The licensee replaced the four valves in June 1986 with valves having Elgiloy springs.
The licensee's review of IN 86-72 consisted of a data base search in September 1986 of Valcor valves and no valves of.the model number listed in the IN were found.
This search would have failed to identify the above mentioned valves since they had a different model number.
The IN did not specify that only the listed model number could be affected.
IN 86-72 was not reviewed by an individual for the determination if any
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other model numbers of Valcor valves could have 17-7 PH stainless steel springs.
Two other Valcor valves were found on the database and are in a low temperature demineralized water system therefore the IN does not apply.
IN 86-72 and associated 10 CFR 21 Report are considered closed.
In summary, the following concerns exist with respect to IN distribution and followup:
a.
Distribution may not include the cognizant individual and no record of detailed distribution is maintained.
b.
IN assignment for action is not timely c.
Evaluation of the issues are superficial and persons most knowledgeable of the issues are often not contacted.
No violations or deviations were identified.
9.
IE Compliance Bulletin (Closed) Bulletin 86-03:
Potential Failure of Multiple ECCS Pumps Due to Single Failure of Air Operated Valve in Minimum flow Recirculation Line.
Consumers Power responded to this bulletin on November 12, 1986 stating that Palisades design is not susceptible to a single failure of the type described above.
The Safety System Functional Inspection (SSFI) conducted in October 1986 identified a concern with a single safety grade air supply to the series recirculation valves which might not close on a recirculation actuation signal.
Since the valves are powered from separate busses, fall open on loss of electric power, are normally open and " fail as is" on loss of air, the licensee concluded that the ECCS pumps were not subject to common mode failure.
The licensee is continuing to evaluate the potential for exceeding 10 CFR 100 off-site dose limits and the feasibility of an air system modification.
The licensee expects to resolve this issue prior to startup.
Resolution of the single failure susceptible air supply is being tracked as an unresolved item from the SSFI Report No. (255/86029-02(SSFI).
No violations or deviations were identified.
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10.
Procedures
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- The inspectors review procedures and procedure changes on an ongoing basis.
Several discussions had been held during the inspection period with the licensee on the proper use of temporary changes notices-(TCNs).
One of the inspector's concern relate to the use of TCNs to change the scope or method of the procedure.
Although the processing of TCNs is in-accordance with the Technical Specifications, TCNs are being used to make quick changes and enhancements instead of using the more lengthy process of' procedure revisicn.
Administrative Procedure 10.41, " Procedure on Procedures", limits the use of TCNs to cases _that do not change the intent of the procedure.
It appears that " change of intent" is not'
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clearly understood by all of the individuals who write TCNs.
Another concern of the inspector is that since TCNs are not subject to the same degree of review as a procedure revision, issues addressed by the TCN are lacking appropriate reviews including safety evaluations.
For example, most operations procedure revisions are reviewed by the Plant Review Committee (PRC), ALARA, Technical, Safety Evaluation, Environmental, and Quality Assurance. A TCN is reviewed by only two PRC members, one of whom must hold a Senior Reactor Operators license.
A final concern relates to the excessive use of TCNs. For example, Administrative Procedure 5.01, Revision 7, " Processing Work-Orders / Work-Request," was recently issued with five TCNs already incorporated.
On June 20, 1986, Administrative Procedure 10.41, Revision 8 was issued which changed the allowed number of TCNs to a procedure before revision from six to twenty.
The issue of appropriate TCN usage will be tracked as Unresolved Item 255/86031-03 (DRP) pending further review by the inspectors.
At the management exit the licensee stated that plans were being formulated to address the problems identified with TCN usage.
No violations but one Unresolved item was identified.
11. Motor-0perated Valve Meeting On November 17, 1986, representatives of Consumers Power Company, (denoted in Paragraph 1) met with the NRC staff (as denoted) in-the Region III office to discuss the licensee's plan of action to address SafetySystemFunctionalInspection(SSFI)teamidentified)otor-operated valve (MOV) concerns.
The SSFI concerns addressed include enviro *nmental qualification of lubricant, torque and limit switch settings and. thermal overload sizing.
The licensee's presentation included what has been.-
found and done so far and what will be done prior to plant startup.'
Prior to startup, four MOVs which have an unqualified grease in them will be regreased; an inspection of all Q-listed MOVs wilh be completed which
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includes verification of the wiring, grease reliefs and T-drains and any
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deficiencies resolved; torque switch settings will be verified or adjusted to within the approved range; and the stems of Q-listed valves will be lubricated.
During the 1987 maintenance outage, the licensee plans to relubricate all Q-listed M0Vs not previously done and as many non-Q-listed valves as possible with the remainder to be completed during the next refueling outage.
Thermal overload sizing will be studied further by the licensee in conjunction with Appendix R.
The licensee has agreed to provide a letter to the NRC outlining the M0V inspections to be done this outage including a schedule and an inspection checklist.
Following the inspections the licensee will submit the results to the NRC.
The licensee's plan appears to address the SSFI identified M0V concerns.
12.
Motor-0perated Valve Physical Condition The licensee's valve inspection and maintenance activities were discussed with respect to commitments made in a meeting on November 17, 1986, at the Region III Office and in a letter dated November 21, 1986, to Region III Administrator J. Keppler.
It was determined that the commitments were being addressed and would be completed as agreed to.
A pt,1ysical inspection of four valves, coincident with the licensee's activities, indicated that the valves are being relubricated as necessary and that the torque switches are being reset to within the nominal to maximum values provided by Limitorque.
Grease reliefs, T-drains, motor leads, and other environmental qualification items were being inspected and corrected as necessary.
The licensee indicated that none of the 46 safety-related motor-operated valves would contain SUN EP50 grease on startup, assuring environmental qualification of the valve gear case and motor pinion gear lubrication.
Other concerns are being addressed by the licensee in the longer term, including development of a comprehensive preventive maintenance program and implementing their response to IE Bulletin 85-03.
Further concerns for valve geared limit switch and torque switch settings are to be addressed in the bulletin response activities.
This is expected to take place during a 1987 maintenance outage.
Also, a refurbishment of all Q-listed valve motor operators will be performed during this outage.
13.
Design Changes and Modifications Facility Change FC-707 modified the containment sump Recirculation Actuation System (RAS) to eliminate the potential for a single failure of apowersupplytocausealossofallEngineeredSafeguardpumps.
This modification changed the actuation logic from "2 nf 4 to "1 of 2 twice".
The following aspects of this change were reviewed: review and approvals including 10 CFR 50.59 reviews, installation and testing procedures, results of testing resolution of deficiencies, operating procedure and drawing revisions, operator training, and Technical Specification (TS)
change request submittal.
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During review of the Safety Evaluation for the change it was'noted that
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although TS changes are required to provide controls to prevent inadvertent actuation, the licensee concluded that the margin of safety as defined in the basis for the TS was not reduced.
This was based on the fact that the previous design was deficient making the TS requirements inappropriate.
Also noted during review was a generic issue concerning the power fuses to the circuit.
Since it is a standby circuit, there is no indication that power is available.
If the fuse'is installed upside down or if fuses are blown there is no means of external identification.
This issue is rede.iving further consideration under resolution of ER-86-067.
No violations or deviations were identified.
14. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
An unresolved item disclosed during the inspection are
~ disclosed in Paragraph 10.
15. Open Items Open items are matters which have oeen discussed with the licensee, which will be reviewed further by the inspectors, 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 6 and 7.
16. Management Interview A management interview was conducted on December 8, 1986, following the inspection.
The scope and findings of the inspection were discussed.
The inspectors also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as proprietary.
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