IR 05000255/1989010

Forwards Update to post-accident Sample Monitor Sys,Per 890616 Insp Rept 50-255/89-10.Line Items Reevaluated W/ Regards to Manpower,Design Criteria & Requirement to Meet NUREG-0373 Commitments

ML18054A919
Person / Time
Site:	Palisades
Issue date:	08/15/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8908210092
Download: ML18054A919 (16)

Text

• * * General Offices: 1945 West Parnall Road. Jackson, Ml 49201 * (517) 788-1636 August 15, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -INSPECTION REPORT 89010 UPDATE Kenneth W Berry Director Nuclear Licensing Inspection Report 50-255/89010 dated June 16, 1989 requested an update to our action plan for improving Post Accident Sample Monitor System (PASM) reliability, i.e., open item 50-255/89010-0 During an August 1, 1989 telephone conversation with your staff we indicated Consumers Power Company would submit this update by August 15, 1989. The updated PASM action plan is enclose Since NRC receipt of the previous PASM action plan numerous line items have been re-evaluated with regards to manpower, design criteria and the requirement to meet our NUREG-0737 commitment This re-evaluation has resulted in the action item due dates in the attached plan. Inspection Report 89010 also requested a description of our plans for improving Quality Assurance oversight of vendor laboratories providing radiological analysis for strontium and yttrium. The present Quality Assurance supplier qualification program requires that this laboratory be audited every three years. The most recent audit was completed in the latter part of 1988. Findings from the audit have been satisfactorily closed and the audit was evaluated as acceptabl Another audit has been scheduled for October 30, 1989. The audit team will include the Corporate Health Physicist as a technical specialis The supplier qualification program will be reviewed pending the results of this audit . OC0889-0102-NL04

• Nuclear Regulatory Commission Palisades Plant Inspection Report 89010 Update August 15, 1989 The inspector who conducted Inspection Report 89010 expressed a concern regarding our review of vendor analyse Normal radwaste samples analyzed by the vendor are checked by a monthly surveillance required by Health Physics Procedure 10.01. -j/ /

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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector-Palisades Attachment OC0889-0102-NL04

• * * OC0889-0102-NL04 ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PASM UPGRADE ACTION LIST August 15, 1989 13 Pages *

• ITEM MODIFY UNRELIABLE COMPONENTS-Replace TE-1901, TE-1902 & TE-1903 -Replace PI-1907, PI-1908 & PI-1909 -Reduce number of lok connections WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION Replace entire instrument loop with ANSI type K component ANSI type K thermocouple elements have increased corrosion tance to sample flow and will thus have a longer life. Replace mechanical pressure cators and their diaphragms with electrical transducers and digital indicator Mechanical Pis have frequently gone out of tion due to rupture of the phragm. Swagelok connections are tible to developing leakage, especially in presence of high system pressure Swagelok connections also, however, vide greater ease in performing maintenanc Need to deterraine locations where it would be ficial to replace some of the Swagelok connections with welded component SC has been tiated. Parts are being procure Engineering now in progres Completed evaluation of those Swagelok fittings most ceptible to ing leakage. This was done by ing w.o. history from Jan. 1986 to present. Swagelok fittings upstream of PCS sample cooler were noted as source of fitting leakage on 15 of those total 17 total w.o. 's REFERENCE SC-89-044 FC-841 WBS 43090 UPDATED 8/15/89 DUE. ASSIGNMENT DATE TCSaarela RJCorbett TCSaarela 1990 Maint Out, 1990 Maint Outage 1990 Maint Out Page 1

• ITEM DESCRIPTION MODIFY UNRELIABLE COMPONENTS (cont'd) .. WORKLOAD/TCS/MAOS PASM LIST STATUS/RESOLUTION related to fitting leakage. ESSR and project record were generated on 5/4/89 to replace those Swagelok fittings with welded fitting REFERENCE UPDATED DUE. ASSIGNMENT DATE Page 2

• ITEM COMPLETE INLINE MONITORING PROJECT -Implement changes to Dissolved Oxygen C00 2 l Analyzer and Gas Chromatograph (GC). * -Install longer piece of tubing between MV-1907 and MV-1925 to provide proper volume for undiluted sample. -.Complete project acceptance test T-FC-676- Provide seal-in relays for LPSI and PCS sample valves SV-1914 and SV-1916. WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION Instruments have not performed in an acceptable manner. System was modified due to previous erratic sample volumes. System now provides consistent sample volumes of 3) ml. Sample volumes need to be 4 ml. Test is needed to verify factory completion of project. Change corrects previous modification STATUS/RESOLUTION After initial revised design, 00 2 analyzer continued to have problem Vendor continuing to evaluate design changes needed to make D0 2 analyzer work properl Design change has been implemented for Gas Chromotograph (GC). Design has been revised to orage a 1/8" coiled sample loop. New sample loop has been ordered. Delivery is ted in mid Septembe Only punch list items remain to be complete Work was arily suspende Work now being resumed. REFERENCE FC-676 w.o. 24902506 EDC-FC-676-1 (Item was added scope to inline monitoring project).

FC-676 FC-676 EDC-FC-676-16 UPDATED 8/15/89 ASSIGNMENT GGKennedy 9/15/89 GGKennedy 10/1/89 GGKennedy 10/15/89 GGKennedy 9/15/89 Page 3 ITEM COOPLETE INLINE MONITORING PROJECT Complete Chemistry Dept. Training for mod. WORKLOAD/TCS/MAOS DESCRIPTION (cont'd) Need to complete training for Chemistry technician LIST STATUS/RESOLUTION Training to be performed after modification is complete This will allow use of panel for training. edure for PASM operation will also be revised at that time. REFERENCE FC-676 UPDATED 8/15/8 DU ASSIGNMENT DATE JPaver/ TChartrand 1/1/90 Page 4

• ITEM EVALUATE PASM DESIGN AND IMPLEMENT CHANGES AS NECESSARY-Compare and evaluate alternate systems and designs. -Verify PASM samples are consistent with NSSS samples. -Evaluate and implement recommendations for optimizing design of PASM Component WORKLOAD/TCS/MAOS DESCRIPTION Action is needed to learn more about common industry problems and solution Need to intPract with other utilities to learn optimum*desig Action is needed to reverify Chemistry's ability to take accurate post accident samples. This action is based on servative approach to PASM evaluation (i.e. reason for verification is not due to suspect design). As a result of walkdown and review of Panel, vendor is recommending some minor design changes to enhance operation of several component STATUS/RESOLUTION Completed May 4, 1989. PASM/NSSS samples are consistent with each other. REFERENCE Reviewed vendor mendations from Sentry letter dated 5/15/89. Couple of items on list have been complete In addition, a couple of the recommendations are included as ate items on this action list. Following other changes were determined to be propriate to implement (Specification Changes need to be initiated for these items): UPDATED ASSIGNMENT DATE TCSaarela/

TAChartrand TChartrand TCSaarela 12/31/89 Completed 6/31/90 Page 5

• I * PASM UP ITEM DESCRIPTION EVALUATE PASM DESIGN AND IMPLEMENT (cont'd) CHANGES AS NECESSARY-Evaluate concern about loss of control air (N 2 l to PASM panel valves CV-1912, CV-1913 & CV-1917. -Consider replacing various PASM system globe *valves with ball or plug valves. WORKLOAD/TCS/MAOS CV-1912 and CV-1913 fail closed upon loss of control air. Valves need to be open for samplin Need to determine what happens to CV-1917 on loss of air. CV-1917 is new 5-way control valve. PASM system control air is Q-Liste Globe valves are susceptible to developing seat leakage. Ball or plug valves are less apt to develop seat leakage. Globe valves, however, provide better throttling capabilit Need to determine which valves should be considered for out. CTION LIST STATUS/RESOLUTION-Replace sample needles -Replace septums -Revise range of conductivity cell (CE-1902)

Also still need to consider revising N 2 pressure reqd for purging undiluted sample lines. Air evaluation complete Design for control air to PASM Panel vlvs is adequate as is. Determination has completed on valves which should be replace Nine valves should be replace Energy Supply Services Request (ESSR) has been initiated to effect completion of modificatio REFERENCE ASSIGNMENT A-PAL-89-052 TCSaarela TCSaarela Complete 1990 Ma int Outage Page 6 PASM UPGRADE ACTION LIST * ITEM DESCRIPTION UPGRADE TIMELINESS OF MAINTENANCE-Provide higher priorities Assign higher priorities for W.O.s for Work Orders -Upgrade spare parts for PASM system -Upgrade PM program for PASM Maint. WORKLOAD/TCS/MAOS of PASM and associated sampling component Include those W.O.s on Ops Concerns List. When assigning priorities Ops needs to also identify if PASM system is inoperable or not due to maintenanc Review spare parts program PASM and upgrade as require Currently 4 PMs exist for either calibration of PASM instruments or maintenance of valves, tubing and gaskets. Vendor has informally proposed a service contract for per.'..,)dic inspection and maintenance of the panel. STATUS/RESOLUTION W.O.s related to inoperability of PASM are assigned as Priority 1 and put on the Ops Concerns List. Other W.O.s in PASM system are assigned a lower priorit This has been in effect since 5/1/89. Energy Supply Services Request (ESSR) initiated on 5/19/89 to effect upgrade of PASM system spare parts program. Vendor provided letter on 5/8/89 with scope of activities which could be included in service contrac Completed review of vendor letter. UPDATED 8/15/89 REFERENCE ASSIGNMENT DWKaupa Completed TCSaarela 8/1/90 TCSaarela 1/1/90 Page 7

• ITEM DESCRIPTION PASM LIST STATUS/RESOLUTION UPGRADE TIMELINESS OF MAINTENANCE (cont'd) WORKLOAD/TCS/MAOS Use of vendor personnel to PM type inspections as well as completing maintenance appears to be beneficia Vendor to perform PM on PASM Panel starting in January 1990. PMs to include exercise (and review) of system, tion of inline moni-* toring type eqpt, preventative maint. of various components and verification/

testing for proper operations of other component Need to develop contract and issue Purchase Order. REFERENCE ASSIGNMENT DU DATE Page 8

• * PASM UPGRADE ACTION LIST ITEM DESCRIPTION EVALUATE AND UPGRADE ADMINISTRATIVE RESOURCES ASSOCIATED WITH SYSTEM -Revise Chemistry Sampling Procedures-Evaluate and upgrade drawings -Upgrade Equipment Data Base and Q-List WORKLOAD/TCS/MA05 Chemistry Procedures need to be updated and technicians trained regarding procedure changes. New P&ID M219 Sh 2A has ancies. Various electrical drawings in vendor file are awkward. During recent war-dow of a PASM W.O. one electrical drawing was found to be incorrec Drawings should be reviewed and upgrade Not all PASM components are in EDB, some components are not appropriately identified (eg V-18) and others do no.t have Q-List Interpretation EDB and Q-List need to be updated. STATUS/RESOLUTION Procedure revision was completed 5/19/89. Procedures will also be revised upon completion of inline monitoring project. Technicians will be trained on inline monitoring mod at that time. See action under "Complete Inline Monitoring Project" for followu Procedure revision for M219 Sh 2A was ated on 5/18/89. Form 40 was written to MTNordin on 5/9/89 requesting his action. Action assigned to JAHanks. Energy Supply Services Request (ESSR) ted on 7/24/89 to REFERENCE effect upgrade using ESS Group. UPDATED 8/15/89 DU ASSIGNMENT DATE Torn Chartrand Completed TCSaarela JAHanks TCSaarela P&ID Rev. Completed Electrical Drawings 12/31/89 9/31/90 Page 9

• ITEM DESCRIPTION EVALUATE AND UPGRADE ADMINISTRATIVE (Cont'd) RESOURCES ASSOCIATED WITH SYSTEM WORKLOAD/TCS/MAOS Numerous system designations are used for PASM components (eg PCS, ESS, MGS, WGS). To help define PASM system boundaries, it is highly recommended that a new system designation (eg PAS) be provided to all PASM component STATUS/RESOLUTION REFERENCE Subsequently it was mined that work would be better done using the Configuration Control Project Group since they are performing similar type work on other Plant systems. UPDATED 8/15/89 ASSIGNMENT Page 10 ITEM IMPLEMENT MISCELLANEOUS IMPROVEMENTS TO PASM SYSTEM -Change Sample Cask Wheels -Delete PI-1914 -Change tubing configuration to PI-1900 WORKLOAD/TCS/MAOS DESCRIPTION PASH LIST STATUS/RESOLUTION Metal wheels of sample cask marks up aux bldg floor when transporting samples to .hot or grey labs. Need to evaluate alternate design (eg rubber wheels). Need to initiate SC to remove PI and replace with plug. PI'S inside of panel and not accessible during normal operation and or post dent condition PI is used only for maintenanc I&C would prefer to use temporary test gauge when performing maintenanc Reduce length of tubing line to PI-1900 to reduce vibration on fitting Add tee in line to PI-1900 to provide test connection for system hydro (RC-78). Currently test connection for system hydro is provided by removing PI-1900. Changes would reduce wear on Swagelok fittings associated with PI-1900. No action taken at this time. No action taken at this time. Modification to be completed as part of project for ducing number of Swagelok connections in PASM system. Engineering Services Supply Request has been initiated as part of project to reduce number of Swagelok connections in sample line. REFERENCE ASSIGNMENT TCSaarela TCSaarela TCSaarela DUE DATE 12/31/90 1990 Maint Outage 1990 Maint Outage Page 11 ITEM PASM MAINTENANCE ITEMS -PI-1903 -PCV-1916 -MV-1932 -EC-103-1 WORKLOAD/TCS/MA05

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DESCRIPTION PI-1903 not responding properl PT-1904 needs to be replaced and calibrate PT is stock item, however current balance on hand is zero. Valve is unable to throttle sample flow to value required by Chem Proc. Need to install new PCV. Handle rotates more than 90-( ie, handle appears to be slipping on shaft) Complete PM for inspection maintenance of septums and filters. Also check and tighten any loose valve handles. STATUS/RESOLUTION New transmitter was installed on 6/22/89. New valve was installed on 6/21/89. WO being planned. Chemistry Technician completed PM type activity to replace septums and 0-rings on undiluted needle assembl Other panel septums appear to be o.k. Chemistry has also tightened all loose valve handles. Filters are not ing and have been determined to be acceptabl REFERENCE WO 24902329 PO 1009-3258 WO 24903286 WO 24902918 UPDATED 8/15/89 ASSIGNMENT TCSaarela Completed TCSaarela Completed TCSaarela 10/1/89 TCSaarela Completed Page 12 PASM MAINTENANCE ITEMS -EC-168 WORKLOAD/TCS/MAOS

• DESCRIPTION

-, UPGRADE ACTION LIST (cont'd) Replace relay module in annunciator panel for high sample temperature alarm. Needs a replacement relay module. Replacement relay was installed on 6/22/89 UPDATED 8/15/89 REFERENCE ASSIGNMENT WO 24802876 TCSaarela Completed Page 13