IR 05000255/1989012
| ML18054A780 | |
| Person / Time | |
|---|---|
| Site: | Palisades |
| Issue date: | 05/23/1989 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A779 | List: |
| References | |
| 50-255-89-12, GL-87-12, NUDOCS 8906050331 | |
| Download: ML18054A780 (17) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89012(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:
April 11 through May 8, 1989 Inspectors:
E. R. Swanson J. K. Heller A~ Beckman
~-~-~~
Approved By:
Bruce L. ~~~i"'"
Reactor Projects Section 2A Inspection Summary License No. DPR-20
.s-p:s/<:!7 Date Inspection on April 11 through May 8, 1989 (Report No. 50-255/89012(DRP))
Areas Inspected: Routine unannounced inspection by the resident inspectors of: actions on previously identified items; operational safety verification; radiological controls; maintenance; surveillance; security; reportable events; NRC generic letters; and allegation No Safety Issues Management System (SIMS)
items were reviewe Results:
No violations, deviations, open items or unresolved items were identifie The inspection did not disclose any noteworthy weaknesses in the licensee's programs or practice The inspection noted strengths in the operators prompt response to the April 18, 1989 loss of condenser cooling event which prevented a plant trip, and in the successful completion of NRC monitored requalification exams of all eight licensed operator :3906050331 8'::>052]
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- 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
- W. L. Beckman, Radiological Services Manager R. A. Fenech, Operations Superintendent
- R. M. Massa, Acting Operations Superintendent
- H. C. Tawney, Mechanical Maintenance Superintendent
- K. M. Haas, Reactor Engineering Superintendent K. E. Osborne, Projects Superintendent
- C. S. Kozup, Licensing Engineer
- J. R. Brunet, Licensing Analyst D. J. Malone, Licensing Analyst R. J. Frigo, Operations Staff Support Supervisor
- R. E. McCaleb, QA Director
- R. P. Margol, QA Administrator Nuclear Regulatory Commission (NRC)
- E. R. Swanson, Senior Resident Inspector
- J. K. Heller, Resident Inspector
- Denotes those present at the Management Interview on May 10, 198 Other members of the Plant staff, and several members of the Contract Security Force, were also contacted during the inspection perio.
Actions on Previously Identified Items (92701, 92702, 37828, 92720) The SEP items listed below are bejng removed from the Region III Open Item list, because the actions requiring Region III inspection have been completed and documented in previous inspection report The actions requiring NRR/Licensee resolution are identified on NRR tracking system Paragraphs 2.b, c and d, of Inspection Repor,t No. 255/89007, provided the latest status of Items (2), (3)
and (4) belo (1)
(Closed) Open Item 255/04S06-0l(DRP)):
Procedures to achieve cold shutdown with alternate water sources. Actions necessary to resolve this issue by the licensee are awaiting NRR followu The licensee cannot resolve the issue procedurally without NRR input. Given that NRR is tracking this item, and closeout of this issue will identify any inspection items necessary by NRC or the resident inspection staff, this item is considered close *-***-----*----- - *---*---- -- ---***.----------*----*-*-* -*----..-* -**
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(2)
(Closed) O~en Item 255/04S10-00(DRP)):
Completion of seismic design eva uations for specific component (3)
(Closed) Open Item 255/04S12-00(DRP)):
Evaluation of specific structural load (4)
(Closed) Open Item 255/04S15-02(DRP)):
Submit a revised Technical Specificatio~ for Pr.imary Coolant leakage detection syste (Closed) Unresolved Item 255/82015-02(DRP)}:
Paragraph 3.4.1 of Technical Specification 3.4, 11Containment Cooling" requires operability of the containment cooling syste Paragraph 3. allows inoperability of components listed in Paragraph 3.4.1, provided the redundant components are tested. The Technical Specification Definition or Basis Section did not define the term
"Redundant Components" and the licensee's interpretation was not consisten Numerous requests to NRR for a definition were submitted, however, a definition was never provided. Technical Specification Change 104 was issued to remove ~ component from Paragraph 3.4.1 ~nd 3. In addition, Technical Specification Basis was revised and included an example of redundant componen This item is clos*ed based on the example provided in the Basi (Closed) Open Item 255/85034-02(DRP}):
LER 255/85028 documented that the right safety injection channel failed to actuate when a construction acti'vity caused the left safety injection channel to actuate. The LER did not discuss why the right channel failed to actuate. The open item remained open pending a revision to the LER, discussing failure of the right channel to operat LER 255/85028 Revision 1 was issued on November 9, 198 The revision provided five possible equipment malfunctions that could prevent equipment operatio However, the revision discounts each malfunctio Surveillance testing performed since the malfunction, has not reproduced or identified the failure mechanis The conclusion reached is that the failure was not repeatable and that a similar failure has not occurre (Closed) Open Item 255/86014-04(DRP)): This Open Item indicated that the licensee did not consider the upper guide structure a core component and was therefore exempt from Technical Specification 3.8.1,
"Refueling Conditions".
The open item also stated that since core components are not defined, the licensee would submit an interpretation to NRR for revie Discussion with the Technical Engineer indicated that because of problems encountered during the 88 refueling outage, the licensee now considers the upper guide structure to be a core component and a revised letter of interpretation is planned for submittal to NR (Closed) *Unresolved Item 255/86018-04(DRP)):
This unresolved item questions if Administrative Procedure 5.01, Attachment 4B incorrectly classified work activities as 11skill of the craft".
Verifying 11skill of the craft" is an item that the inspector
- routinely confirms when maintenance activities are observe No recent problems with this nave been identified, and since this is routinely observed, this unresolved item is close (Closed) Violation 255/86023-0l(DRP)):
This Violation lists several examples of improperly planned maintenance activities. The licensee's responses dated October 26, 1986, December 23, 1986 and February 6, 1987, address these concerns and.have resolved the Violatio (Closed) Open Item 255/86023-07(DRP)):
Containment air room purge valves CV-1813 and CV-1814 were required to be electrically locked closed above cold shutdow However, the licensee determined that a start of a purge fan would override the locking mechanism and open the valve Internal correspondence RJC 86*004 documents that the interlocks between the purge fan and valves CV-1813 and 1814 were removed per W.O. 24607447 and Specification Change 86-28 The inspector has reviewed W.O. 24607447 and Specification Change 86-281 and has no additional question (Closed) Open Item 255/86027-0l(DRP)):
Containment Isolation valve CV-1813 and CV-1814 were stroked {see Open Item 255/86023-07(DRP),
closed in Paragraph 2.g above) by the operators without use of an approved test procedure or work order. The crew documented in Shift Supervisor Log Book 152, Page 82 dated August 30, 1986, that the valves were stroked by normal means without the use of special lineup, lifted leads or jumper In addition the log entry shows the plant was in cold shutdown, a p1ant condition that would permit stroking of the valves or operation of the purge fa For this case, it is not apparent that a special test procedure was require The in~pector has no additional question (Closed) Open Item 255/86035-03(DRP)):
Replace spray valves CV-1059 and CV-1057 as part of the Five Year Pla The original Material Condition Task Force based the planned replacement on a perceived problem with spare parts availability. The valves had been successfully overhauled in 1986, and subsequent evaluation by the licensee determined that the spare parts problem was not unavailability but long lead times. Spare parts needs were reassessed and parts-on-hand requirements upgraded to avoid lead time problem As a result, the licensee has concluded that replacement will not be necessar (Closed) Open Item 255/86035-14(DRP)):
Establish a baseline compressed air performance test. The licensee's Material Condition Task Force, Item CAS~Ol, had identified a need to establish a performance baseline for the compressed air systems from which future problems could be predicted and corrected prior to component failur The systems of interest are the high pressure, low volume safeguards air system and the low pressure, high volume instrument air system *
- . The licensee developed and initially conducted special test T-205, High Pressure Air System Performance Verification Test, in late 1986, to establish baseline capacity and leak rate dat The test identified and initiated corrective actions for various system capacity and leakage problem The test was partially performed as a retest for those repairs in early 1987. A review of the test results, relevant internal correspondence and current system status, with the systems engineer, indicated that the system has been relatively trouble free since the last test and repairs. T-205 is scheduled for performance on an 18 month frequenc Because of relatively few problems, this system is not included in routine trend analysi The instrument air system has been the most problematic of the air systems due to compressor reliability and capacity problem The inspector reviewed the 1987-89 quarterly trend data, trend evaluation reports, and the system's maintenance history; found that the licensee had replaced the "B" compressor with a higher capacity rotary unit, and had instituted preventive maintenance on the remaining reciprocatiRg "A" and "C" compressor The current maintenance history indicated that the licensee's measures appeared to be effectiv (Closed) Open Item 255/86035-29(DRP));
Establish a procedure for installation of internal parts in the hotwell sample and radwaste caustic injection pumps, and methods to prevent piping and fitting leaks.: The licensee has incorporated technical manual references and detailed work steps into the stand.ing work orders applicable to these tasks. The inspector visually observed the hotwell sample pumps to confirm that the instructions appeared appropriate and that the material condition of the pumps was acceptabl (Closed) OTen Item 255/86035-44(DRP)):
Repair Boric Acid Heat Tracing.his item involved the long term repair and restoration to as-built conditions of the boric acid heat trace control panel, EC-3 Failures, constant alarm conditions, and control circuit problems, in the panel, had been identified by two Deviation Reports Nos. PAL-84-367 and PAL-83-17 The licensee had conducted system performance surveys and evaluations to identify discrepancies, had corrected the material discrepancies, and had issued a Setpoint Change document, No. SPC-86-015, to correct improper control and alarm setpoints. The inspector reviewed the above documentation and inspected the subject panel and verified that the alarm and controls setpoints were properly set and that the system was operating satisfactorily. The only discrepancy noted, was an alarm on non-Q circuit No. 453, and it had already been identified by the*
licensee while performing Work Request 13556 (Closed) Open Item 255/86035-49(DRP)):
Incorporate diesel generator alarm reflash capability. Diesel generator local alarm panels previously did not have reflash capability for the group trouble alarm on the main control boar Facility Change FC-627-2 replaced local alarm panels G20 and G30 (1-1, 1-2 Emergency Diesel Generators, respectively) with panels having reflash capabilit *
- The inspector reviewed the above FC package, discussed the systems operation and function with control room operators, inspected the local panels, and verified that the alarm response procedure (ARP-20, Revision 45) accurately reflected the new as-built configuratio (Closed) Open Item 255/86035-64(DRP)):
Install new packing configuration on SIRW Tank outlet isolation valves CV-3031 and CV-305 The valves wer~ repacked using new style graphite packing during the 1988 refueling outage (Work Orders 24804889 and 24605609 respectively). The original commitment included establishment of a leakage trending program after repacking, however the licensee had determined that to be unnecessary based on the high integrity demonstrated by the graphite packing syste The inspector reviewed licensee packing performance data, inspected CV-3031, and found no current indication of packing leakage problem (Closed) Open Item 255/86035-76(DRP)):
Replace Sprinkler Fire Alarm Panel C-47. The alarm panel, located behind the main control board, did not previously have alarm reflash capability for its group
trouble alarm on the main control boar The panel was replaced by Facility Change FC-755 with a new panel having more alarm windows and having reflash capability. The inspector reviewed the FC installation and test records, inspected the new panel installation, discussed system operation and function with control room operators, reviewed Surveillance Procedure S0-6, Fire System Sprinkler
.
Alarm Surveillance Test, Revision 2, verified that the procedure reflected current system configuratio (Closed) Open Item 255/86035-79(DRP)):
Evaluate calibration frequency of feedwater regulating circuitry. The initially identified problem were concerned with the stability of the feed water pump speed control circuit in automatic operation, and whether the 18 month calibration frequency was adequat The licensee had concluded that more frequent calibration was not necessar Internal correspondent MAF89*004 concluded that most prior problems were due to component failures, not calibration induced problems, or drift. Further, the system had undergone a major overhaul and tuning in 1986-87, apparently substantially improving its performance. The inspector reviewed the maintenance history and discussed current system performance and stability with control room operators, and found that the system's feed pump speed control performance had been acceptabl (Closed) Open Item 255/86035-107(DRP)):
Ensure operability of monitor RIA-2316, Fuel Handling Area Monito The monitor provides
~ontainment isolation for refueling accidents and is used only during fuel handlin The Material Control Task Force identified previous chronic problems with monitor failures and spurious isolations. These problems were characterized as minor although numerou The licensee has scheduled and budgeted the unit for replacement during calendar year 1990 as part of the Five Year Pla One of the more common failures resulted from overly sensitive reed
- switches actuating when the unit was bumped by passing personne As an interim measure, a protective cage has been built around the monito The* combination of limited operation, the protective cage, and routine surveillance testing appears adequate to ensure continued operability until the unit can be replace (Closed) Open Item 255/86035-132(DRP)):
Investigate sources of vibration in Control Room Air Conditioners VC-10 and VC-11, and proposed modifications to resolve. The originally reported problem *
was the freon leaks caused by metal identification tag holders.wearing through tubin Gauge vibration damage had also been observe The licensee has replaced the metal tag holders with soft nylon
"tie-wraps" eliminating the former proble The latter gauge problem has been partially resolved by replacement of original gauges with oil-filled gauges and with in-line gauge oscillation dampeners (snubbers).
The units were inspected while operating on April 28, 1989, and were found to be functioning satisfactorily with no abnormal vibrations. Further, the maintenance history was reviewed, for both units, and no significant recurrence of prior problems was found since 1986-87 corrective action (Closed) Olen Item 255/86035-141(DRP)):
Logic Diagram E-17 and PPAC ESS017 inc uded incorrect references to the hydrazine and sodium hydroxide tank The System Functional Evaluation (SFE) found that the above documents incorrectly add'ressed tank T-102, the hydrazine tank, as the sodium hydroxide tank. Both the PPAC and logic diagram had been revised and correctly referenced the tank by both the proper mark number and noun nam (Closed) Open Item 255/86035-145(DRP)):
Licensee will complete systems training for System Engineer As part of the initial program development, the licensee had committed to providing systems tr~ining for System Engineer The inspector reviewed training records for all staff members, except SRO licensed supervisors, and verified that the systems training had been complete The only exceptions were individuals who had recently been assigned; and discussions with the department superintendent determined that these individuals were scheduled for this trainin (Closed) Open Item 255/86035-158(DRP)):
Implement a leak testing program for check valves between safety and non-safety air system Special Test T-205, "High Pressure Air System Performance Verification Test," Revision 2, includes inter-system check valve testing for the interfaces between the East and West Safeguards High Pressure Air systems and the low pressure system The test had initially been performed in late 1986 arid had identified leaking check valve The valves were subsequently replaced and successfully tested in February, 1987. Test T-205 is scheduled for 18 month recurrent performance in accordance with PPAC OPS43 No violations, deviations, unresolved or open items were identifie * *
Operational Safety Verification (71707, 93702, 42700)
Routine facility operating activities were observed as conducted in the plant and from the main control room Plant startup, steady power operation, plant shutdown, and system(s) lineup and operation were observed as applicabl The performance of licensed Reactor Operators and* Senior Reactor Operators; of Shift Technical Advisors, and of auxiliary equipment operators was observed and evaluated including procedure use and adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie Evaluation, corrective action, and response for off normal conditions or events, if any, were examine This included compliance to any reporting requirement Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems and nuclear reactor protection systems, as applicabl Reviews of surveillance, equipment condition, and tagout logs were conducte Proper return to service of selected components was verifie The following activities were observed: General The unit operated at approximately 80 percent power during this reporting period. A 80 percent power limit had been administratively imposed by the licensee to resolve NRC questions pertaining to steam generator tube leakag The licensee has agreed not to Jncrease power without prior discussion with NRC personne The May steam generator inspection outage has been deferred until October. The licensee briefed NRC personnel on their plans to defer the outage until October 1989 during a management meeting held in Washington on May The outage is projected for 45 day During the briefing licensee personnel discussed steam generator mechanical tube plug problems, provided additional information on recent tube plug cracking problems and provided a justification for operation until the October outag NRC personnel are reviewi~g the information provided by the license Charcoal Absorbers Below Technical Specification Requirement The licensee's Internal Quality Assurance audit conducted on April 12, 1989, found that charcoal absorbers used in the Spent Fuel Pool Ventilation System had an efficiency less than required per Technical Specifications. The licensee had replaced the charcoal beds with charcoal that had not been tested prior to the replacement and were subsequently found unacceptabl The sample taken after replacement was analyzed, however, it was never compared
- with the Technical Specification acceptance criteri As a result, during the refueling outage operations and heavy load movements, in the vicinity of the Spent Fuel Pool, activities occurred while the charcoal absorbers were in the unacceptable conditio The licensee initially determined that this was a 10 CFR 50.73 Reportable Event and not 10 CFR 50.72 reportabl The inspector requested that a second review for 10 CFR so*. 72 reportabi l i ty be mad After completing the second review, the 1-icensee determined that this was also 10 CFR 50.72 reportabl~ and made the appropriate notification The inspector does not have additional questions at
.this time, however, additional reviews will be made when the Licensee Event Report is issue Head Pressurizer Vents During the reporting period PIA 1066,"Gaseous Vent Pressure Gauge",
slowly increased and alarmed, indicating that the first isolation valve from either the pressurizer or head vent path was leakin PIA 1066 is located between the first and second isolation valves of the syste The operators confirmed that primary leakrate, containment activity, and pressurizer quench tank pressure were stable and not increasing. With these indicators stable, leakage past the second isolation valve was not presen The above actions were required by Alarm Response Procedure (ARP) 33, Item 1 ARP 33 also required valve cycling to set a leaking valve and also relieve the pressure buildu The crew choose not to cycle the valves because the installed valves are Target Rock valves, which have a history of sealing problems when cycled against a high Differential Pressure. A change to the procedure was made to eliminate the need to cycle the valve The licensee plans to perform a special test to identify the leaking valve, initiate repair, and determine the root caus Operator Response To A Transient On May 1, while attempting to remove a dilution water pump from service for ma.intenance, condenser vacuum started decreasing and one of two cooling towers basin levels started to increas The operators responded to the potential loss of a cooling tower by reducing Reactor/Turbine power from 80 percent to approximately 40 percent in two minute The operator actions appeared appropriate and probably prevented a turbine trip (and reactor trip)
from low condenser vacuu Shortly after the transient, the inspector reviewed control room indications and verified that operating parameter remained within the expected band Post transient review indicated that the draining of the isolated Dilution water pump piping permitted air leakage past two closed butterfly valve The tagout was properly executed and the licensee concluded that the butterfly valves would not normally be expected
..
to be leak tight. Apparently the work planners either did not expect the valves to leak, or did not identify the potential air pathway to the condense The work was cancelled, work orders initiated to inspect the two valves and power returned to 80 percent following the plant standing orders pertaining to power escalation rate Containment Tendon Grease During a protected area tour the inspector observed grease on the side of the containment. This was discussed with the system engineer. This inspector asked if tendon grease was leaking and whether this could effect operability of the tendon The engineer explained that the tendon grease is normally solid but will liquify at temperatures near 100 degrees Fahrenheit, a condition that existed this past summe The grease may have leaked past the funnel/trumpet connection of the tendon assembl The engineer stated that the amount of grease observed should not effect operability of the tendons or containmen The engineer also stated that grease liquification is a known industry problem and is an item targeted for resolution on the licensee 1s five year pla Tour Items During plant general tours the inspectors identified the following items for licensee resolution:
(1) Several air leaks associated with valves, dampers, and fittings all had work requests initiated, but some of the work requests have existed for awhile. The licensee was asked at the exit meeting to review the priority_given to these item (2)
The 1-1 Diesel Generator governor oil level was found to be high (above scribe work). Operators took prompt action to correct the oil level. The inspector recommended that the licensee review their training for auxiliary operators, since this condition had been identified by the inspector several times over the last yea Operator Regualification Exams During the week of April 17, 1989, eight Licensed Reactor and Senior Reactor Operators were examined under the cognizance of the NRC and all passed the three portions of the exam successfully. Some enhancements in the examination methodology were recommended by the NRC Team, with only one concern being expressed (relative to the control rod mimic status panel and operator response to the lack bf a light).
No violations, deviations, unresolved or open items were identified *
- Radiological Controls (71707)
During routine tours of radiologically controlled plant facilities or areas, the inspector observed occupational radiation safety practices by the radiation protection staff and other worker Effluent releases were routinely checked, including examination of on-line recorder traces, and the proper operation.of automatic monitoring equipmen *
Independent surveys were performed in various radiologically controlled area The licensee is installing a new "Fast-Scan" whole body counte A tour with the Radiological Services Manager identified no significant material or housekeeping concern No violations, deviations, unresolved or open items were identifie.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repairs} and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl The focus of the inspection was to assure the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specifications. The following items were considered during this review:
the Limiting Conditions for Operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl The following activities were inspected:
. w.o. 24902087 w.o. 24901773 w.o. 24902500 w.o. 24902526 e. w.o. 24905520 Repair C-68 Drain Float PPAC ESSOlO - ESS valve air pressure indicators and regulators Delta T power reference calculator meter (DIA-OOlOA) is sticking at Zero Calibrate D/G raw water pressure indicators Trouble shoot SPI analog to digital converter problem
- W.O. 24902085 and W.O. 24902086 Check and repair damper D-13 for leak throug No violations, deviations, unresolved or open items were identified.* Surveillance (61726, 42700)
The inspector reviewed Technical Specifications required surveillance testing as described below and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that Limitin~ Conditions for Operation were met, that removal and restoration of the affected components were properly accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The following activities were inspected: MI-2 Reactor Protective Trip Unit MI-2A Reactor Protective Trip Unit MI-4 Pressurizer Low Pressure SIS Initiate and Pressurizer High Level Alarm * Q0-25 Chemical Addition System Test (T-102/T-103). RT-85C Inplace HEPA & Charcoal Filter Testin RT-85d Inplace HEPA & Charcoal Filter Testin DW0-1 Daily Control Room Surveillanc SH0-1 Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.
Security (71707)
Routine facility security measures, including control of access for vehicles, packages and personnel, were observe Performance of dedicated physical security equipment was verified during inspections in various plant area The activities of the professional security force in maintaining facility security protection were occasionally examined or reviewed, and interviews were occasionally conducted with security force member Tours of the Central and Secondary Alarm station were conducted * Perimeter area alarm checks using personnel and a remotely operated vehicle were observe The inspector visited a zone alarm post (not required to be manned at the time) and found an AM/FM radio present at this pos When asked, the licensee stated that radios are available for use at certain posts and their use is monitored to ensure they do not detract from the guard attentiveness or ability to hear the conununication radi No violations, deviations, unresolved or open items were identifie.
Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Reports (LERs) 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 (Open) LER 255/84021:
Primary coolant pump P-50C failed at the impeller to shaft couplin The licensee had promised to submit a 11detailed analysis of the event 11 as an update to the LER, but their March 23, 1989 revision contained only a cryptic sununary of less than one pag The inspector verified that the analysis was complete and that the licensee intends to revise the LER and take steps to ensure that commitments of this nature are me No violations, deviations, unresolved or open items were identifie * CFR 21 Review (36100)
Consumers Power Company (CPC) received a 10 CFR 21 notification from Rosemount concerning the potential loss of fill fluid on certain transmitter CPC reviewed their records and identified one su~pect transmitter in service (PT-0762C), which had performed satisfactorily in service for over three year Rosemount stated that all known failures have occurred within the first 30 months of service and recommended no action for those performing acceptably for over 36 month The licensee intends to leave this transmitter in service in the Auxiliary Feedwater low suction.pressure trip circuit (2 of 3 required to actuate).
1 NRC Generic Letters (92703, 255101)
(Closed) Generic Letter 255/88017, 87-12 11Loss Of Decay Heat Removal
- Under the guidance of TI-2515/101 the inspector reviewed the licensee's 60 day response dated January 3, 1989, and made the following observation Training Training was conducted as stated and new training modules are under development for the annual training of the operators in reduced inventory operations and for the new task of equipment hatch closure. Adequate provisions are in place to ensure that operators are trained in the latest procedural and equipment changes that occur prior to the conduct of reduced inventory operation * Co.nta i nment Closure The licensee has demonstrated the ability to achieve containment closure in less than the most restrictive time calculated before boiling could occur. Plant practice is to station maintenance personnel at the equipment hatch during periods of reduced inventory operations, with the sole responsibility of closing.the hatch on the-Shift Supervisor's direction. Standing Operating Procedure (SOP) 1 Attachment 5, currently assigns responsibilities for this function and for the control of other penetrations and hoses & lines which
, may obstruct their closur Temperature Indication The licensee does not currently meet the requirement for 11 independence 11, in that the core exit thermocouples are not redundan The temperature monitoring can be read on the control room panels, the plant compu~er display or the Critical Function Monitor which also provides historical and trending data. These capabilities and the applicable procedures appear to adequately address this issu *
Water Level Indication Two independent continuous Primary *Coolant System (P~S) level indicators meeting the Generic Letter requirements do not exist.
One remote indicator is provided for control room display, and an alarm is provided on Primary Coolant Pump (PCP) low discharge pressure which indicates deteriorating flow conditions as a result of low level in PC Additionally a hard-piped level glass is installed, and a Reactor Level Monitoring System is available for monitoring level below the top of the hot leg and above the fue Operating experience has demonstrated that these systems apparently provide adequate operator information to monitor PCS level and take effective corrective actions when neede However, since an acceptable independent instrument is not currently available to monitor level within the hot legs, the *licensee is planning to install another level instrument to provide more accurate leg level indication for control room operators. This action will be initiated under Progra1T111ed Enhancement (1), committed to be installed during the 1990 refueling outag PCS Perturbations SOP-1 assigns the responsibility for review and scheduling of activities, potentially affecting PCS level or cooling support systems, to the Shift Supervisor and the Operations Support Scheduler, an SRO qualified individual, who screens and schedules all maintenance and testing. These individuals have demonstrated conscientious and competent performance in this functional are PCS Inventory SOP-1 requires one boric acid flow path to be operable at all times which may utilize a charging pump, containment spray pump, gravity feed from the SIRW tank or a high pressure safety injection (HPSI)
pump with the ability to enable a second HPSI pump within 30 minute An Engineering Analysis (EA-GP-88-1215) evaluated the flow rate requirements and validated the flow path Hot Leg Flow Paths Procedure SOP-1 requires that if both hot legs are blocked with nozzle dams, that the Pressurizer manway be removed to provide a vent path for the PC Combustion Engineering has analyzed this vent path and concluded that it meets the Generic Letter requirement The Steam Generator dam installation procedure specify the installation of the hot leg dams last and their removal firs Loop Stop Valves The Palisades plant design does not incorporate loop stop valve The licensee's January 31, 1989 response outlining future enhancements was not reviewe No violations, deviations, unresolved or open items were identifie. Allegation Review (92705, 99014)
(Closed) RIII-88-A-0136 Concern NRC Region III received an anonymous allegation that hoists operating over the Spent Fuel Pit did not have an override feature which resulted in heavy loads hanging near the edge of the pi NRC Review On November 9, 1988 the allegation was forwarded to the licensee requesting a review to determine if operating procedures, administrative controls, and the physical configuration of hoists handling heavy loads in the vicinity of the Spent Fuel Pit were adequate and if activities of this nature were being properly conducted. A discussion of the investigation and any steps taken to resolve the allegation was also requeste The licensee responded by letter dated December 12, 198 The response addressed the operating procedures and administrative controls for handling heavy loads in the vicinity of the spent fuel pit but did not address the physical configuration as requeste The response described the system interlocks which prevent movement of loads within four feet of
- the fuel pool, the bypass keys available to override these interlocks, a limited discussion of the administrative controls on the bypass keys, and the dates of three successful verifications of these interlock function The response did not indicate whether or not there had been occurrences of heavy loads moved over the spent fuel pit and no evidence was provide9 to support the conclusion of adherence to existing administrative control To gather the information necessary to resolve the concern, the inspector interviewed the plant safety engineer who conducted the investigation and reviewed applicable procedures and work request The following documents were reviewed:
- Technical Specification 3.21, Movement of Heavy Loads
- Procedure No. FHS-M-23, dated 6/10/88, Movement of Heavy Loads in the Spent Fuel Pool Area
- Procedure*No. MSE-E-1, dated 1/24/86, Overhead Crane Electrical Inspection
- PPAC FHS021, Preventive Maintenance of Fuel Pool Crane
- Nuclear Work Order No. 076762,-dated 6/16/88
- Nuclear Work Order No. 105956, dated 8/9/88
- Nuclear Work Order No. 126101, dated 3/3/89 PPAC FHS021 and MSE-E-1 comprise the monthly testing of the Fuel Pool Crane interlocks which prevent heavy-loads from moving within four feet of the edge of the poo The inspector reviewed records which showed satisfactory performance of the interlocks for calendar year 198 FHS-M-23 provides guidelines for the movement of heavy loads in the Spent Fuel Pool area, defines safe load paths for movement of heavy loads, provides the steps required for approval to move a heavy load over an alternate path (which includes over the spent fuel pool), provides the documentation of review and approval of alternate load paths, and instructions for issuance and control of the Spent Fuel Pool Crane bypass key No movement of the crane over the Spent Fuel Pool can occur without one or both of these key *
The three nuclear work orders were occurrences of heavy loads moved in the Spent Fuel Pool area. All were properly completed and documented the review and approval of heavy load movement including use of the crane bypass key The inspector noted from Attachment 3 to FHS-M-23, that load path 1 includes the entire western edge and a portion of the southern edge of the Spent Fuel Pool and that a load following path 1 could be*at the edge of.the pool providing the bypass keys were in us Work Order 105956 to move 5300 pound shield blocks is an example of the use of load path 1 with the crane byp?ss keys specifie Conclusion Alternately stated, the allegation claims there are no interlocks on the Spent Fuel Crane which results in loads hanging near the edge of the pi The inspector determined that appropriate interlocks are installed on the crane and that these interlocks have been operable throughout 198 From
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interviews and review of the work orders, the inspector determined that heavy loads are occasionally moved near or over the Spent Fuel Pool, that adequate administrative controls are in place, and that plant personnel comply with these controls. Absent a specific occurrence and having reviewed records of three properly completed moves, the inspector concludes that the alleger observed a movement of a heavy load similar to that of work order 105956 and was unaware of the existing administrative controls. This allegation is not substantiated and is considered close. Management Interview (30703)
The inspectors met with licensee representatives. (denoted in Paragraph 1)
on May 10, 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 inspection. The licensee did not identify any such documents/processes as proprietar