IR 05000255/1989002
| ML18054A587 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/02/1989 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A586 | List: |
| References | |
| 50-255-89-02, 50-255-89-2, NUDOCS 8903140532 | |
| Download: ML18054A587 (6) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89002(DRP)
Docket No. 50-255 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 License No. DPR-20 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
January 10 through February 6, 1989 Inspector:
E. R. Swanson Approved By: B.~ef
.~ Reactor Projects Section 2A nspection Summary Inspection on January 10 through February 6, 1989 (Report No. 50-255/89002(DRP).)
Areas Inspected:
Routine unannounced inspection by the resident inspector of: followup and reportable event.
Results:
One potential violation was identified concerning 50.59 review of a modificatio In addition, one unresolved item was identified concerning operability of the Control Room HVAC Syste The inspection disclosed weaknesses in the licensee's 10 CFR 50.59 review proces The inspection noted strengths in the licensee's corrective action system in the timely
identification and response to the Control Room HVAC test failure, including the supplemental notifications and correspondence to the NR DETAILS Persons Contacted Consumers Power Company
- G. B. Slade, Plant General Manager
- J. G. Lewis, Technical Director R. D. Orosz, Engineering and Maintenance Manager R. M. Rice, Operations Manager H. C. Tawney, Mechanical Maintenance Superintendent
- D. J. Malone, Licensing Analyst C. S. Kozup, Licensing Engineer R. A. Fenech, Operations Superintendent G. J. Daggett, System Engineer L. T. Phillips, System Engineer Nuclear Regulatory Commission {NRC)
- E. R. Swanson, Senior Resident Inspector
- J. K. Heller, Resident Inspector Other members of th~ plant and corporate staff were also contacted briefl *Denotes those present at the Management Interview on Feb.ruary 6, 1989 Actions on Previously Identified Items {92701, 61726, 64704, 37700, 40500)
{Closed) Unresolved Item 255/88018-0l{DRP):
Performance of refueling outage test Ro..:.28, "Control Room/TSC Ventilation" on August 21, 1988, resulted in the discovery that the emergency mode was apparently inoperable as a result of open electrical penetration The modification which removed the fire barrier seals apparently did not receive adequate review under 10 CFR 50.59 td ensure that control room (CR) habitability concerns were addresse The Palisades Technical Specifications do not address the revised heating, ventilation and air conditioning (HVAC)
system which was installed in 1983 to meet TMI Item III.D.3.4 commitment However, it is apparent that the CR HVAC system as found did not demonstrate compliance with General Design Criterion 19 as then analyze The unresolved item from the prior report is being closed and one new unresolved item is being opened to track the unresolved concern for the system operability (255/89002-0l(DRP)). Also, one potential violation was identified regarding an inadequate 10 CFR 50.59 review (255/89002-02{DRP)). Safety Review The modification being performed by the licensee involved the removal of asbestos fire barrier material between cable trays in the cable spreading room and in penetrations into the control roo The applicable work order {No. 24802455) was reviewed for potential unreviewed safety questions, but the review failed to consider the
- impact of the barrier removal on the Control Room ventilation system operabilit The review did consider the requirements for the raceways, separation, and fire protection. A separate review evaluated the scaffolding impact on equipment operabilit Administrative Procedure 3.07 11Safety Evaluations 11 provides adequate guidance for the performance of review However, a weakness in the rev*iew process exists in that no* list of items to evaluate is part of.the procedur The design review process involves a checklist of considerations, but in the case of a work order it need not be utilized. The inspector could identify no explicit requirement to perform the safety review which was performe The fact that one was done is t~ the credit of the engineers involved and demonstrates their cautious approach to conducting the wor Had a Specification Change or modification package been generated related to this work order, the administrative procedure would have required a safety review. The alternate (non-asbestos) materials used for the fire barrier installation was evaluated by an engineering analysis and installed under a*n existing Permanent Maintenance Procedure (FPS-E-1).
10 CFR 50.59 permits changes to be made to a facility provided the changes do not involve a change to the technical specifications (TS) or involve an unreviewed safety question (USQ).
A change is deemed to involve an USQ if (a*mong other things) it may increase the consequences of an accident or malfunction of equipment important to safety previously evaluated by the NR It appears *that the CR HVAC System was degraded so as to adversely affect the consequences of an accident. This item is considered a potential violation of 10 CFR 50.59 requirement Operability The test failure on August 22, 1988 indicated a positive pressure of 0.020 inches water gage, which provided some measure of protection against in-leakag The system design and analysis was based on the assumption that a positive pressure of 0.125 inches would be maintaine A subsequent CR Habitability analysis (EA-P-CRAVS-881005)
concluded that a positive pressure need not be maintained in the CR during cold shutdown and refueling, provided the penetrations can be sealed within 30 minute This analysis considered a fuel handling accident and incorporated a dose reduction by taking credit for operability of the Spent Fuel Pool HVAC System during fuel handlin A new analysis of the Maximum Hypothetical Accident (MHA) performed by the licensee, to address operability requirements during operation, determined that vestibules would be required to meet GDC 19 due to errors currently identified during a review of the original analysi The use of qualified vestibules eliminated a 10 CFM in-leakage penalty from the analysi Results of the MHA analysis demonstrated compliance with General Design Criterion 19 to limit exposure to CR occupants to 5 REM whole body equivalent, using ICRP 30 methodolog Results of the analysis with vestibules resulted in a calculated 4.86 whole body equivalent dos Given an
84% degradation in the system's ability to maintain positive pressure in the CR, and the proximity of the estimated dose to the.
design limit, it appeared that the CR HVAC System was significantly degraded during previous plant operatio An assessment of operability using the NRC approved analysis of record (NRC SER dated April 29, 1983), before the factor of four increase from the previous analysis due to identified errors has not been conducted. Since the 1983 analysis was the basis for operability at the time of the penetration issue discovery, it was appropriate to evaluate operability (in relation to a potential violation) on that basis. Additional reviews of the operability concerns need to be conducted by both the NRC and the licensee. Other hypothetical challenges to the system are presently being analyzed and will be available to the NRC for review by February 20, 1989. A revision to the LER is planned to be submitted by March 31, 198 Corrective Actions The test failure occurred with the plant in cold shutdown when no fuel handling was taking plac During this plant condition, no analyzed threats to control room habitability existe The following actions were taken or are planned:
(1)
Due to the immediate inability to determine the operability*
of* the CR HVAC System, a 10 CFR 50.72 report was* made on August 22, 1988. Since the plant was in cold shutdown, the only analyzed concern was for a fuel handling acciden No fuel handling was therefore allowed until the analysis of (3) below was complete.
(2)
The ten penetrations which were found open were temporarily sealed and the test was re-performed satisfactorily on August 23, 198 (3)
An analysis completed on August 27, 1988, established that the maximum open area of a penetration in the CR envelope, during fuel movement, to maintain operability of the system, was 266 square inches. A subsequent analysis showed that sealing of penetrations within 30 minutes of a fuel handling event would provide adequate protection. Therefore, the licensee concluded that a 1/8 inch water gauge positive pressure with respect to the surrounding areas need not be maintained during plant shutdow (4)
Revised Technical Specifications were outlined in an August 30, 1988 letter to the NRC, which incorporated the results of the above analysi (5)
The licensee submitted LER 88-013 on September 22, 198 (6)
Vestibules were established for two of four control room door The modification work, testing and evaluation were reviewed by the inspector and found acceptable. Administrative controls for the remaining doors were also reviewe One door into the CR did not appear to be adequately controlled and the licensee tentatively agreed to modify their administrative controls on
. December 9, 198 The Plant Review Committee concluded, after review*of the issue, that locking the door would provide a barrier to rapid operator access to the Cable Spreading Room, and that the door would not be locke This change of plans was not communicated to the inspector who reviewed the issue on February 6, 1989 *and found that the door was sti 11 not controll~d properly, nor had a basis for operating without administrative control of this non-vestibule door been established. Subsequent to the exit meeting the inspector learned that the door would now be locked during the times the CR HVAC System was required to operate in the emergency mode until an engineered resolution can be achieve (7) A retest of the CR HVAC on November 11, 1988, demonstrated twice the required 1/8 inch water gage positive pressure with respect to surrounding area (8) While performing a new analysis it was determined that the previous CR habitability study, which established the design basis for the CR HVAC system (reviewed by NRC SER dated April 29, 1983), was in error. Several factors resulted in a f~ctor of four non-conservative error. This discovery was reported on October 27*, 1988 under 10 CFR 50.72. A discussion of this was included in Revision 1 to LER 88-013, submitted o November 17, 198 (9) After establishing vestibules to eliminate unfiltered in-leakage to the CR, an analysis using lCRP 30 methodology was completed
- for the maximum hypothetical accident which showed compliance with the requirements of General Design Criterion 1 (10) Further analysis which will go beyond the FSAR accidents are being performed, as described in a December 20, 1988 letter to the NRC, the results of which should be available by February 20, 198 (11) The Licensee's review of the 10 CFR 50.59 reviews, performed in support of the subject modifications, concluded that they were inadequat Corrective action to the review process was already underway in response to prior problem It invo-lves the intensive training of a qualified review group, which will then provide a consistent high level of 50.59 review NRC approval of a Technical Sp~cification change to permit the associated reorganization is being actively sough One unresolved item was identifie One violation, no deviations, and no open items were identifie.
Reportable Events (92700)
The inspector reviewed the following Licensee Event Report (LER) by means of direct observation, discussions with licensee personnel, and review of record The review addressed.compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/88013 and Revision 1: August 22, 1988, inoperable Control Room ventilation systems (see Paragraph 2).
No new violations, deviations, unresolved or open items were identifie.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved Items disclosed during the inspection are discussed in Paragraph.
Management Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1)
on February 6, 1989 to discuss the scope and findings of the inspectio In addition, the inspector also *discussed the likely informational
content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents/processes as proprietar