IR 05000255/1988016
| ML18053A454 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/19/1988 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18053A452 | List: |
| References | |
| 50-255-88-16, NUDOCS 8807280339 | |
| Download: ML18053A454 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report No. 50-255/88016(DRP)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
June 2 through July 6, 1988 Inspectors:
Eric R. Swanson Approved By:
C. D. Anderson
~.l,cyz.,-n-B. L. Burg&ss, Chief Reactor Projects Section 2A
"Inspection Summary License No. DPR-20 Inspection on June 2 through July 6, 1988 (Report No. 50-255/88016(DRP))
Areas Inspected:
Routine, unannounced inspection by resident inspectors of followup of previous inspection findings; operational safety; maintenance; surveillance; physical security; radiological protection; licensee event reports; and engineered safety feature walkdow Results:
Of the areas inspected, no violations or deviations were identifie Two uncited violations, one for failing to meet test requirements and one for failing to have a continuous fire watch, are discussed in Paragraph 8 as Licensee Event Report Another violation not cited is discussed in Paragraph 3.b for a modification that was made with inappropriate controls in 198 An Open Item is discussed in Paragraph 3.d to track the possible bypass regulator modification/TS change.
8807280339 PDR ADOCK Q
880719 05000255 PNU
- *
DETAILS Persons Contacted Consumers Power Company (CPCo)
+# D. P. Hoffman, Vice President-Nuclear Operations
+#*G. B. Slade, Plant General Manager
+#K. W. Berry, Director, Nuclear Licensing
+#M. R. Wade, Project Manager J. G. Lewis, Technical Directnr W. L. Beckman, Radiological Services Manager
- R. D. Orosz, Engineering and Maintenance Manager
- R. M. Rice, Operations Manager
- D. W. Joos, Administrative and Planning Manager
- C. S. Kozup, Licensing Engineer
- R. A. Vincent, Plant Safety Engineering Administrator
+#*D. J. Malone, Licensing Analyst
- R. E. McCaleb, Quality Assurance Director
- R. A. Fenech, Operations Superintendent T. J. Palmisano, Plant Engineering Supervisor H. C. Tawney, Mechanical Maintenance Supervisor R. J. Frigo, Operations Staff Support Supervisor
+#R. L. Scudder, Sr. Engineer, Plant Projects
+#K. E. Osborne, Projects Superintendent
+B. a. Meredith, Sr. Engineer, Plant Projects
+K. A. Toner, Supervisory Engineer
- M. D. Mennucci, Radiation Safety Supervisor
- J. R. Brunet, Licensing
+V. S. Nuemann, Consultant, NUS
+P. A. Di Benedetto, Consultant, OBA, In Nuclear Regulatory Commission (NRC)
+#C. J. Paperiello, Deputy Regional Administrator
+H. J. Miller, Director, Division of Reactor Safety
+J. J. Harrison, Chief, Engineering Branch
+H. J. Wong, Deputy Director, Office of Enforcement
+J. A. Grobe, Director, Enforcement
+#W. L. Axelson, Chief, Reactor Projects Branch 2
+U. Potapovs, Section Chief, Office of Nuclear Reactor Regulation
+#B. L. Burgess, Chief, Projects Section 2A
+R. N. Gardner, Chief, Plant Systems Section
+#E. R. Swanson, Senior Resident Inspector
- C. D. Anderson, Resident Inspector
+M. J. Kopp, Reactor Inspector
+A. S. Gautam, EQ Lead Inspector
+#T. V. Wambach, Project Manager
+W. H. Schultz, Enforcement Coordinator
+#R. C. Kazmar, Projects Inspector
- Denotes those present at the Quarterly Management Meeting, June 24, 198 +Denotes those present at the Environmental Qualification Enforcement Conference, June 24, 198 *Denotes those present at the Management Interview on July 5, 198 Other members of the Plant staff, and several members of the Contract Security Force, we~e also contacted briefl.
Followup of Previous Inspection Findings (92701 and 92702)
(Closed) Open Item 255/84013-0l(DRP): Determination of the cause for the exces~ively high temperature of cables in cable tray CP-250 inside containmen Actions were completed as documented in Report No. 50-255/85009(DRP), page This item is close (Closed) Unresolved Item 255/86003-03(DRP): Apparent lack of timely resolution of chemical control concern The inspector reviewed the licensee's chemical control program determining that thorough and routine uncontrolled chemical inventory inspections are performe The technician performing the inspection reports the findings directly to the Environmental Coordinator (EC).
The EC then addresses each finding, taking action as appropriate through the applicable department head responsible for the uncontrolled chemica The implementation and maintenance of this program appears to satisfy previous chemical control concern This item is closed.
(Closed) Violation 255/86014-05(DRP): Inadequate Auxiliary Feedwater (AFW) pump testin The licensee's test program for the AFW ~ystem did not meet 10 CFR 50, Appendix B, Criterion XI, requiring a test program be established ensuring that testing is performed in accordance with written test procedures which incorporate or reference the requirements and acceptance limits contained in applicable design documents (i.e., FSAR design analysis).
The licensee has revised the AFW testing program that provides verification that the AFW pumps meet design flow requirements on an eighteen month basi The FSAR was revised to reflect the actual requirements of the AFW syste It is noted that during resolution of this violation the licensee determined that a lack of knowledge of design basis requirements was a problem common to all safety related pump system In response, the licensee initiated the System Functional Evaluation and Configuration Control Project programs to resolve the identified concern This item is close No violations or deviations were identifie.
Operational Safety (71707) Routine Inspections The inspectors observed control room activities, discussed these activities with plant operators, and reviewed various logs and other operations records throughout the inspectio Control room indicators and alarms, log sheets, turnover sheets, and equipment status boards were routinely checked against operating requirement ~
~
Pump and valve controls were verified to be proper for applicable plant condition On several occasions, the inspectors observed shift turnover activities and shift briefing meeting The inspector also observed some new fuel receipt activitie Tours were conducted in the turbine and auxiliary buildings, and in the 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 requirement A portion of the inspection activities were conducted at times other than the normal work wee An ongoing review of licensee corrective action program items at the Deviation Report level was performe Error In MHA Analysis During the preparation for submittal of a revision to the Paltsades Technical Specifications for containment integrity, it was concluded on June 9, 1988 that an error was made in the existing Maximum Hypothetical Accident (MHA) analysis (FSAR Section 14.22).
This unanalyzed condition was reported to the NRC at 2:35 p.m. on June 9, 1988 in accordance with 10 CFR 50.72(b)(ii)(B).
The error was essentially that a containment vent pathway existed which was not isolated instantaneously at the start of the accident, but at some time between 10 and 25 seconds afterward This would result in a significant increase in offsite dose to just below the 10 CFR 100 1 imi The vent pathway was created in May 1980 by the removal of a rupture disk from a clean waste receiver tank inside containmen This created a vent path to the vent gas collection header which vents outside containment through isolation valve After restrictions were placed on the purge and vent valves due to design concerns, this modification provided a pressure relief path for the containmen A work order was used to remove the rupture disk, but no modification package was identified which would have resulted in design and 10 CFR 50.59 review A justification for continued operation (JCO) was prepared and reviewed by the Plant Review Committee (PRC) on June 10, 198 The PRC concurred in the JCO and concluded that the issue is an unreviewed safety question and requires NRC revie Violations of design control and 10 CFR 50.59 review requirements occurred in 1980 when the rupture disk was remove The licensee has made numerous revisions to their modification process since 198 By current procedures, the removal of the rupture disk would constitute a plant modification and as such would have required the appropriate review In accordance with 10 CFR 2, Appendix C, no violation will be issued for this licensee identified violation (255/88016-0l(DRP).
The licensee will be submitting a Licensee Event Report in accordance with 10 CFR 50.7..*
.. *
- On June 21, 1988, the inspector discovered a fire extinguisher that had not been inspected within the appropriate perio No work was in progress at the time. The Hot Work Permit correctly indicated the last inspection date but neither the job supervisor nor the shift supervisor, who signed the permit, identified the proble Upon notification by the inspector, the Fire Protection Supervisor had the fire extinguisher inspected and initiated a corrective action documen No further concerns were identifie On June 24, 1988, the licensee identified and reported to the NRC a possible failure to meet the single failure criterion of design for the preferred AC buses (Y-10, -20, -30, and -40) when powered from the instrument bus (Y-01) through the bypass regulator instead of its associated inverte Only one preferred AC bus can be powered from Y-01 at a tim The plant was modified to this configuration during the late 1970 If Y-20 was on the bypass regulator and a loss of offsite power occurred, failure of the 1-1 diesel generator (DG) to start (or failure of its breaker to close) would fail both trains of safety injection and containment spray and all non-instrument AC powe This is because the left channel Safety Injection Signal (SIS) relays, sequencers, and DG 1-2 breaker control relay are all fed from Y-2 If offsite power was lost and DG 1-1 failed, both Y-10 and Y-20 would be dead; no right channel SIS would be generated; the left channel pumps would have no power; the 1-2 DG breaker would not auto close; and its sequencer could not be used. If Y-40 was on the bypass regulator and a loss of offsite power occurred and 1-1 DG failed, containment spray would fai These problems are due to putting a 11 right channel 11 bus to the-11 left side 11 *
In addition, putting left side bus Y-30 on the bypass regulator directly fails the automatic loading of the 1-1 DG since the relay which provides the auto close signal to the 1-1 DG breaker is powered from Y-3 Currently the licensee has in place procedures to compensate for the design deficiencie Also the licensee is considering the preferred AC bus inoperable if it is powered from the bypass regulator and will enter the applicable Technical Specification (TS).
The licensee is evaluating options for modifications to eliminate the problem and possibly change T These actions will be tracked as Open Item 50-255/88016-02(DRP).
In the past, the licensee did not consider the preferred AC buses inoperable if on the bypass regulator and have probably been in that condition for longer than the TS allowed eight hour The licensee plans to submit an Licensee Event Report in accordance with
10 CFR 50.7 On July 1, 1988 the licensee determined and reported, in accordance with NRC Bulletin 88-05, that three flanges manufactured by West Jersey Manufacturing Co. were inaccessible during power operations due to being inside containmen These flanges are located on the service water system outlet of the containment air cooler The material is SAlOS, heat No. 2383 The licensee is performing a Justification for Continued Operatio No other violations or deviations were identifie *
I 4.
Maintenance (62703)
The inspector reviewed and/or observed the following selected work activities and verified whether appropriate procedures were in effect controlling removal from and return to service, hold points, verification testing, fire prevention/protection, radiological controls, and cleanliness where applicable: Calibration of E-6A Pressure Switch (HED 24802467). C-2C Air Compressor Inspection (CAS 24802902) (Portion).
No violations or deviations were identifie.
Surveillance (61726)
The inspectors reviewed surveillance activities to ascertain compliance with scheduling requirements and to verify compliance with requirements relating to procedures, removal from and return to service, personnel qualifications, and documentatio The following test activities were inspected: M0-38 DW0-1 SH0-1 Auxiliary Feedwater Pump Testin Daily Control Room Surveillanc Operators Shift Surveillanc No violations or deviations were identifie.
Physical Security (71881)
The inspectors observed physical security activities at various locations throughout the protected and vital areas including the Central and Secondary Alarm Station Periodic observations of access control activities including proper personnel identification, badging and searches of personnel, packages and vehicles were conducte The inspectors verified appropriate security force staffing and operability of search equipmen Protected and vital area boundaries were toured to verify maintenance of integrit Illumination was verified to be adequate to support patrol and Closed Circuit Television (CCTV) monitor observation CCTV monitor clarity and resolution were also observe The inspectors periodically verified that appropriate compensatory measures were taken for degraded or inoperable equipment and breached boundarie No violations or deviations were identifie.
Radiological Protection (71709)
The inspectors made observations and had discussions concerning radiological safety practices in the radiation controlled areas including:
verification of radiation levels and proper posting; accuracy and currentness of area status sheets; adequacy of and compliance with selected Radiation Work Permits and high radiation
procedures; and the ALARA (As Low As is Reasonably Achievable) progra Implementation of dosimetry requirements, proper personnel survey (frisking) and contamination control (step-off-pad) practices were observe Health Physics logs and dose records were routinely reviewe No violations or deviations were identifie.
Licensee Event Reports (92700)
Through direct observation, discussions with licensee personnel, and review of records, the inspectors examined the following reportable events to determine whether: reportability requirements wnre met; immediate corrective action was accomplished as appropriate; and corrective action to prevent recurrence has been accomplishe (Closed) LER 255/86014: Diesel generator actuation from turbine control system maintenanc While performing maintenance on the turbine generator auto-stop oil pressure system an inadvertent turbine trip signal was generated causing an auto-start of the diesel generators (DG).
The plant was in hot shutdown and the DGs were not loaded onto any safeguards buse The maintenance team (company turbine inspectors supplied from an offsite field maintenance group) failed to fully understand the function of the turbine trip lever thereby neglecting the proper actions necessary to prevent DG actuation during testin The maintenance team and responsible engineer were instructed on this aspect of the syste This LER is close (Closed) LER 255/87035: Personnel error results in temporary loss of shutdown coolin On October 15, 1987, at 6:37 p.m., with the reactor in cold shutdown and primary coolant system (PCS) drained six inches below centerline of the hot and cold legs, Low Pressure Safety Injection (LPSI)
pump P-67A was manually secured from operation due to erratic discharge pressure and flo The erratic discharge pressure and flow were the result of an improperly placed jumper (in place for MOVATS testing) which caused a LPSI discharge valve to cycle open/close The jumper was inadvertently placed on LPSI discharge valve M0-3008 rather than HPSI valve M0-3062 (which had been rebased for testing) due to a transposition error on the field data shee The Control Room Operators were alerted to this condition by the annunciation of a LPSI pump low discharge pressure alar The LPSI pump P-67A was than manually secured by the operato Also, as a result of the cycling valve, water was leaking from the area of the PCS cold leg drains which were opened for maintenanc At 7:05 p.m., the cause of the cycling was identified as an incorrect jumper placement and was immediately removed; LPSI P-67A was restarted and shutdown cooling was restore During the 29 minute period, with shutdown cooling flow isolated, the PCS temperature increased 37 degrees Fahrenhei Six inches of PCS inventory (approximately 1,000 gallons of primary coolant) were lost during the even LPSI pump P-678 was available at all times, and would have been able to provide shutdown cooling flow in the event P-67A faile The root cause of the event was a t~ansposition error on the field data sheet
.
I which went undetected due to lack of adequate second level technical revie The inspector has reviewed the licensee's revised procedural controls concluding the corrective actions taken are adequate to minimize further similar occurrences of this natur This LER is close (Closed) LER 255/88007: Procedural inadequacy resulted in Auxiliary Feedwater Actuation System (AFAS) actuatio The report and corrective actions were reviewed by the inspector and determined to be adequat This LER is close (Closed) LER 255/88008: Data entry in surveillance data base resulted in the failure to complete a ~8quired containment penetration leak rate tes The inspector pointed out that the LER description on pages 3 and 4 state that the plant was in an LCD (Technical Specification (TS) 3.0.3) from 8:10 a.m. until 3:00 p.m. which exceeds the time allotted by TS 3.0.3 (one hour) to initiate a plant shutdow In reality the Plant Review Committee effectively declared the penetration provisionally operable (testing required) within the first hou No violation of the above TS requirements occurre A violation of the test requirements was identified by the licensee and meets the criteria of 10 CFR 2, Appendix C for non-issuance of a Notice of Violation (255/88016-03(DRP)).
(Closed) LER 255/88009: Failure to maintain a continuous fire watch as required by Technical Specification (TS).
Due to asbestos removal work in progress, a continuous fire watch was established due to the potential for scaffolding being erected which interfered with the design capacities of the fire suppression sprinkler syste On three occasions, a particular security officer, who was assigned fire watch responsibilities, left the area from between three to twelve minute The officer was a new hirer who had completed the applicable trainin The officer's employment was terminated and this was determined to be an isolated even Also, this LER serves as a special report in accordance with TS 3.22.3.l to outline the action to return the cable spreading room sprinkler system to servic Asbestos removal work is expected to be completed in August 1988 at which time sprinkler performance will not be hampere The violations of TS were licensee identified and meet the criteria of 10 CFR 2, Appendix C, for non-issuance of a Notice of Violation (255/88016-04(DRP).
No other violations or deviations were identifie.
Engineered Safety Feature Walkdown (71710)
The inspector performed a walkdown of the Left Channel Auxiliary Feedwater system and verified: that each accessible valve in the flowpath was in its required position and operable, that power was aligned for components that actuate on an initiation signal, that essential instrumentation was operable, and that no conditions existed which could adversely affect system operatio No violations or deviations were identifie 1.
I 1 Violations Not Cited Violations which meet the criteria of 10 CFR Part 2, Appendix C, for not issuing a Notice of Violation (where the violation was identified by the licensee; fits in Severity Level IV or V; was reported if required; was or will be corrected within a reasonable time, including measures to prevent recurrence; and was not a violation that could have been prevented by corrective action to a previous violation) are assigned tracking item number Three such violations were identified in this inspection report and are contained in Paragraphs 3.b and.
Enfnrcement Conference An enforcement conference to discuss the results of the inspection of Environmental Equipment Qualification (EEQ) was held on June 24, 1988 and attended as indicated in Paragraph The unresolved items discussed in Inspection Report No. 255/86032(DRS) were discussed in detail in view of the revised EEQ enforcement policy promulgated by Generic Letter 88-07 dated April 7, 198.
Management Meeting A quarterly management meeting was held on June 24, 1988 in the NRC office in Glen Ellyn, Illinois to discuss modifications planned for the upcoming refueling outage, update the status of progress on the Configuration Management Project and the 10 CFR 50.54(f) letter of May 21, 1986, and discuss other management issue The meeting was attended as indicated in Paragraph The status of progress appeared satisfactor The
.-licensee was notified of the Commission's intent to conduct detailed inspection and reviews during the refueling outag.
Management Interview A management interview was conducted on July 5, 1988, upon conclusion of the inspectio The scope and findings of the inspection were discusse The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents/processes as proprietary.
9