IR 05000255/1989018
| ML18054A946 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/08/1989 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054A943 | List: |
| References | |
| 50-255-89-18, NUDOCS 8908310296 | |
| Download: ML18054A946 (20) | |
Text
U_ S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89018(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 Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted: June 13 through July 17, 1989 Inspectors:
E. R. Swanson J. K. Heller M. J. Farber 0. A. Beckman Approved ( ~ \\j\\J~c~;V By:~ L~ Burgess, Chief Reactor Projects Section 2A Inspection Summary Date Inspection on June 13 through July 17, 1989 (Report No. 50-255/89018(DRP))
Areas Inspected:
Routine unannounced inspection by the resident inspectors of: material condition task force review; actions on previously identified items; operation safety verification; radiological controls; maintenance; surveillance; balance of plant inspection; security; reportable events; generic letters; and, allegation revie No Safety Issues Management System (SIMS) items were reviewe Results:
Of the eleven areas inspected, no violations or deviations were identified in nine areas. One violation was identified (failure to implement a temporary modification Paragraphs 3.hh and 6.c) in the remaining two areas.
990811 8908310296 05000255 pDR ADOCK PNU Q
DETAILS Persons Contacted Consumers Power Company G. B. Slade, PlaTit 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
- J. L. Hanson, Operations Superintendent H. C. Tawney, Mechanical Maintenance Superintendent K. E. Osborne, Projects Superintendent R. M. Brzezinski, I&C Superintendent L. K. Kenaga, Radiation Protection Manager
- C. S. Kozup, Licensing Engineer J. R. Brunet, Licensing Analyst
- D. J. Malone, Licensing Analyst Nuclear Regulatory Commission (NRC)
E. R. Swanson, Senior Resident Inspector
- J. K. Heller, Resident Inspector
- Denotes some of those present at the Management Interview on July 24, 198 Other members of the Plant staff, and several members of the Contract Security Force, were also contacted during the inspection perio.
Material Condition Task Force Review (92701, 92702)
As a result of equipment problems contributing to a May 1986, plant trip and transient, Consumers Power Company (CPCo) formed the Material Condition Task Force (MCTF) to broadly identify and correct both restart and lo~g term problems in safety systems and balance of plant system The final MCTF report to NRC identified 222 concerns and approved the recommended resolution Licensee action on these items was reviewed and documented in Inspection Report No. 50-255/8603 That report identified numerous items requiring licensee and NRC follow-u An NRC consultant inspected licensee action on a sample of 57 MCTF inspection open items and violations, and the overall status of the MCTF findings were documented in this and Inspection Report Nos. 50-255/89012 and 50-255/8901 Several of the items were found to require additional licensee attention such as the need for expanded DC power ground isolation procedures, the publication of an overdue report of Augmented Test Program status, and improvements in the safety evaluation processe These and similar specific findings are reported with their respective items in Section 3 belo **
A broader concern was identified with respect to the level of management involvement evident in the MCTF resolution proces Several of the MCTF items had implemented resolutions which deviated from the approved task force recommendation Examples included valve repair in lieu of valve replacement, apparent disregard for periodic inspection and maintenance recommendations, etc. Although the implemented actions appeared acceptable, they were not as extensive as those recommended by the MCTF and appeared to have been implemented without review by the Task Force or equivalent processe Discussions with the Plant Technical Director, Engineering and Maintenance Manager, Plant Operations Manager, and others, confirmed that although the task force recommendations had not been formally revised, the respective managers had remained generally cognizant of the changes in final resolution Further, based on the above concerns, the licensee reviewed these and related MCTF items to confirm management satisfaction with the resolutions and implementation statu Licensee i nterna 1 correspondence JGL 89-011 "Recommended Closeout of Material Condition Task Force" documented that revie addition, the licensee also verified that twenty-seven MCTF actions require long term attention are being adequately controlled via the Year Plan and/or specific outage plan In which Five Not withstanding the above, the licensee's final resolutions were found, in general, to be technically sound and adequately implemente No violations, deviations, unresolved or open items were identifie.
Actions on Previously Identified Items (92701, 92702) (Open) Open Item 255/86035-07(DRP):
Prior to start-up from the 1988 refueling outage the licensee will have in place a detailed DC Bus ground isolation procedur This item was previously inspected (see Inspection Report No. 50-255/88026) at which time the licensee contended that the existing Alarm Response Procedure (ARP) No. 3
"Electrical Auxiliaries and Diesel Generator", and a "DC Ground Troubleshooting Checklist" provided adequate guidanc ARP,No. 3 provided only basic operator actions (attempt to reset alarm, check bus location and ground polarity, etc.)-while the troubleshooting checklist is actually a DC power system load list to be used for determining the system/component effects of opening system breaker The process required that the shift supervisor an system engineer develop a bus isolation rationale for each occurrence using the checklist, and provided no "how-to" guidance and no method for controlling the system lineup changes or assuring proper restoration and independent verificatio On July 10, the Operations Staff Support Supervisor provided the inspector a draft revision to ARP No. 3, which appeared to provide adequate ground isolation guidance, but did not address configuration control or provide provisions for restoration and independent verificatio The licensee advised that these factors would be considered in the final revision which would be issued on or before December 31, 1989.
- (Closed) Open Item 255/86035-4l(DRP);
Evaluate development of a test procedure to determine letdown orifice stop valve leakag Special Test T-224 was developed and initially performed to evaluate valve leakag Two of the three valves were repaired during the 1988 refueling outag The test will be performed on an as-needed basis when the operators identify potentially unacceptable va~ve leakag (Closed) OpeTI Item 255/86035-47(DRP):
Complete plans for replacement of the plant sequence of events monitor and data logging systems by end of 1987 refueling outag A licensee report, "Status of the Palisades Nuclear Plant Process Computer System Replacement,
dated November 19,.1987, was issued to close this ite However, that report provided no specific planning or replacement actions but rather addressed the generic considerations of computer replacemen When the apparent lack of detailed planning was identified, the licensee advised that the responsibility for the activity had been reassigned to another individual and that the replacement activity was being administered under the Five Year Plan as Work Breakdown Item 41570, DTA-0 This represents an example wherein the Material Control Task Force (MCTF) item appears to have been closed without adequate basis or management review resulting in the MCTF commitment not being completed as stipulated by the task forc The management of this and related MCTF items are discussed in Section 2 of this report.
(Closed) Open Item 255/86035-60(DRP):
Add manual control air operation capability to shutdown cooling heat exchanger valves CV-3025 and CV-305 The MCTF concern was backup valve operating capability for loss of shutdown cooling scenario Specification Change SC-88-180 was installed to equip the air operated valves with local manual hand-wheel operators in lieu of the manual air contro The system engineer advised that the change was considered a better design based on the identified concern The apparent deviation between the MCTF resolution and the actual resolution was discussed with CPCo management as reported in Section 2 of this repor (Closed) Open Item 255/86035-6l(DRP):
Replace shutdown cooling heat exchanger inlet and outlet isolation Valves CV-3212, 3213, 3223, and 322 The MCTF 1s documented resolution required valve replacement based on valve operator problems, hot spots, and most significantly, seat leakag The valves were overhauled rather than replaced but the original MCTF approved resolution was not revise The licensee was able to demonstrate that the actual resolution was technically adequate, that appropriate levels of station management were involved in the decision to deviate from the MCTF resolution, and that the actual resolution was properly implemente The apparent deviation between the MCTF resolution and the actual resolution was discussed with CPCo management as reported in Section 2 of this report.
- (Closed) Open ltem 255/86035-62(DRP):
Establish an inspection and rebuild program for shutdown cooling heat exchanger isolation valves CV-3212, 3213, 3223, and 322 This was the MCTF long term action in response to prior valve leakag Similar to Item 255/86035-61 above, the MCTF resolution was not accomplishe Instead, a periodic inspection requirement was established for external valve conditions (not seat leakage/integrity and rebuild considerations).
Again, the apparent deviatio~ between the MCTF resolution and the actual resolutioTI was discussed with CPCo management as reported in Section 2 of this repor The licensee was able to demonstrate that the actual resolution was technically adequate, station management was involved in the decision to deviate from the MCTF resolution, and the actual resolution was properly implemente (Closed) Open Item 255/86035-65(DRP):
Relocate FT-0404, high pressure safety injection (HPSI) pump bypass flow transmitter, to avoid over-ranging instrument during safety injection testing and refueling water (SIRW) tank recirculatio Facility Change FC-0803 replaced the flow instrumentatio The unit was not relocated per the original MCTF recommendation but was replaced with a wider scale instrument. The physical installation was inspected and the modification package records reviewed and found acceptabl (Closed) Open Item 255/86035-69(DRP):
Install live load packing and cap packing gland leak off lines for shutdown cooling inlet isolation valves MV-3015 and MV-301 The modifications above were implemented via Specification Changes SC-86-143 and SC-86-022.
licensee inspections since the modifications have found negligible packing leakag (Closed) Open Item 255/86035-?0(DRP):
Repair safety injection and refueling water (SIRW) Tank lea The MCTF recommended actions and eventual repair of the tank were documented by Deviation Reports 86-44 and 88-24A through 88-24 The final repair of the tank was accomplished during the 1988 refueling outage by replacement of the affected tank penetration The licensee conducted a corrosion analysis of the leaking pipe and concluded that the leakage was caus~d by a galvanic corrosion induced by contact between the aluminum nozzle material and adjacent steel deckin The decking was removed from contact with the penetratio The results of the licensee's analyses, the repair records, and final disposition of the matter were reviewed and found acceptabl (Closed) Open Item 255/86035-82(DRP):
With the assistance of an outside agency, develop and implement a valve packing program and corresponding training progra The licensee has implemented a Valve Improvement Program with the assistance of several major valve and service vendor The program prioritizes packing repairs and replaces old valve packing with state-of-the-art packing configurations including live load packin The program included adequate staffing, worker training by outside agencies, provision of competent technical support, continuing surveillance of valve/repair
-*
k.. n.
performance, and adequate budget support for program continuatio Program performance was extensively assessed and found acceptable during NRC walk-down (Closed) Open Item 255/86035-9l(DRP):
Investigate replacement or modification of pressurizer power operated relief valve and safety
_valve discharge temperature indicator terminations to eliminate connector corrosio The terminations were changed from a line (pin type) connector to a terminal strip and lug arrangement in accordance with Specification Change 87-01 No further problems with termination resistance or continuity had been identifie (Closed) Open Item 255/86035-99(DRP):
Perform Q-list interpretation for radiochemistry lab area radiation monitor RIA-230 The interpretation has been performe The monitor was categorized as 11 Q 11 and the plant equipment data base and related documentation were updated to reflect the proper quality classification (Closed) Open Item 255/86035-122(DRP):
Upgrade EHC piping and fittings per vendor recommendation The upgrades were implemented via Specification Changes SC-86-157, SC-86-177, SC-87-379, SC-88-234 and Facility Changes FC-0773 and FC-078 The inspector walked down the system and found no significant leakag Review of work order histories and operator interviews further indicated the upgrades appear successfu (Closed) Open Item 255/86035-124(DRP):
Test and rebuild moisture separator reheater safety valve Valves RV-0530 through RV-0558 were removed, tested and reinstalled during the 1988 outag Consumers Power Test Report No. 848856070535 documented the as-found and as-left conditions of the valve Although some valves could not be refurbished due to lack of spares, all valves were certified as operable when reinstalle The licensee has included eventual replacement of the valves in the Five Year Pla (Closed) Open Item 255/86035-126(DRP):
Evaluate turbine turning gear problems and develop plans to fi As a result of the MCTF observation, Facility Change FC-0808 was implemented during the 1988 refueling outage installing upgraded control circuitry and synchronizing hardwar The inspector visually observed that turning gear equipment appeared to be in good condition and confirmed via operator discussions that the prior chronic problems had not recurre * (Closed) Open Item 255/86035-127(DRP):
Install temperature control valves on the main generator seal oil syste The MCTF identified that seal oil temperature control problems were contributors to past seal and bearing problems. Facility Change FC-0782 installed temperature control valves and controllers for both air and hydrogen side oil temperature Inspection of the physical installation and review of the modification package found the iicensee 1 s actions acceptable.
- (Closed) Open Item 255/86035-13l(DRP):
Evaluate replacing the aging turbine Electro-Hydraulic Control System (EHC) power supplie The licensee has evaluated and overhauled the seven EHC power supplies under Word Order No. 2460551 The work order acti~ities included extensive diagnostic evaluation and resulted in Work Order No. 24801614 for replacement of aged capacitors in a power supply modul Review of maintenance history and discussions with control room operators indicated that the overall system reliability has been substantially improved witti no chronic 'Problems.. *further, the licensee has included replacement of the system control components in the Five Year Plan for 1991-9 (Closed) Violation 255/86035-136(DRP):
Improper use of Temporary Change Notices (TCNs).
Implementation of licensee corrective and preventive actions specified by the CPCo letter of July 16, 1987, was verified including:
reduction in the use of TCNs; creation of a new 11minor revision process" (MRNs); related administrative procedure changes; and staff trainin Effectiveness was confirmed by review of TCNs and MRNs issued between February and May, 198 (Closed) Open Item 255/86035-138(DRP):
Review test procedures to ensure that all valves which receive an accident signal will repositio Prior inspections found that certain valves receiving safety injection signals (SIS) and safety injection recirculation actuation signals (RAS) were not properly re-positioned for surveillance testing, e.g. valves receiving an SIS shut sional were not verified open prior to tes The licensee issued procedures RT-8C and RT-8D, 11 Engineered Safeguard System - Left (Right) channel Test(s),
11 Revisions 0, and Q0-2, 11 Recirculation Actuation System and Containment Sump Check Valves Tests, 11 Revision 20, which provided for proper pre-test positioning and post-test actuation verificatio (Closed) Open Item 255/86035-143(DRP):
Perform periodic testing of feedwater regulation valve isolation on high steam generator leve Periodic and Predetermined Activity Control Items (PPAC) FWS027 and FWS028, established for the subject testing, appeared adequate and had been performed in November 198 (Closed) Open Item 255/86035-144(DRP):
Prior inspections found an unacceptable backlog of about 200 mechanical maintenance work orders delayed due to lack of planning resource The licensee increased the planning staff and performed daily trending of the work order backlo During the first quarter of 1989, the daily backlog of work orders due to planning holds averaged about 80-85; about 40-50 due to engineering holds and another 40-45 due to parts/materials hold The work activities appeared to be properly prioritized and were receiving direct attention from the Mechanical Maintenance Superintenden During the second quarter of 1989, the work orders on planning hold increased to about 500 as a result of preparations for the late spring outag The outage was postponed until fall,
- and the backlog was slowly dcreasing as the outage work orders were processe The licensee 1 s actions in this regard appeared acceptabl (Closed) Open Item 255/86035-156(DRP):
Modify HPSI pump mini-flow system and procedure to enhance pump surveillance testin Modifications included improvement of flow instrumentation (FT-404, discussed in Section 3.g of this report), installation of mini-flow orifice bypass ~iping and valves to permit higher test flow rates~
and enhancement of test procedure methods and data acquisitio Records of these upgrades and the surveillance procedures performed in February and May were reviewed and found acceptabl {Closed) Open Item 255/86035-159(DRP): Implement a program to leak test instrument air supply check valves for accumulators on component cooling water containment isolation valves CV-0911 and CV-094 The containment isolation valves would fail open on loss of instrument air and are held shut by the accumulators during a containment isolation concurrent with loss of instrument air as per Final Safety Analysis Report (FSAR) Section 9.3.2. Previously the check valves were not testable to ensure that the accumulators could fulfill those requirement Facility Change FC-0788 installed test connections and Special Test T-226, 11 CCS Accumulator Test For CV-0911 and CV-0940, 11 Revision 1, was performed in late 1988, verifying the FSAR functions were satisfie Special Test T-226 has been scheduled for periodic performance by PPAC X-OPS426.
(Closed) Violation 255/87005-01 (DRP):
Improper correction of data errors by use of erasure and correction fluid in lieu of initialled line-through The corrective and preventive actions of the licensee 1 s August 19, 1987 letter were verified complet Also, routine review of documents by the resident inspectors have identified no recurrence (Open) Open Item 255/87005-06(DRP):
Issue report summarizing test results, corrective actions and surveillance program changes resulting from the Augmented Test Program efforts by June 198 The status of this item was previously reported in Inspection Report No. 50-255/8901 On June 26, 1989, the CPCo Plant Technical Director advised that.a report will be provided in September 198 The report was not issued as originally planned through an oversigh The September date is based upon the licensee researching the program history to provide an adequate repor (Closed) Open Item 255/87005-07(DRP):
Verify installation of local temperature indication for the shutdown cooling heat exchanger dis-charge line The inspector reviewed Work Orders No. 24805087 and 24805088, confirming that 50-400 degree F. thermometers were installed in existing thermowells in both outlet line The instruments were verified in place and functional by visual *
observatio **
a (Closed) Violation 255/87008-04(DRP):
Approval of temporary procedure changes by unauthorized individual Implementation of licensee corrective and preventive actions specified by CPCo letter July 3, 1987, was verified including revisions to administrative procedures and implementation via review of temporary procedure changes issued between February and May 198 b (Closed) Open Item 255/87008-05(DRP):
Replace reactor protection matrix relay test switches due to age and wea Licensee Event Report (LER) No. 255/87008 reported an inadvertent reactor trip due to dirty switch contact The licensee replaced the matrix hold button contacts and matrix relay trip select switches (Specification Change No. SC-87-214) during the 1988 refueling outage in accordance with Work Orders No. 24703825 through 24703830 consecutivel Surveillance procedures have also been revised to manually exercise the switches prior to use to pre-clean the contacts using the switches'
self-wiping featur Discussions with instrumentation and controls and operations personnel confirmed that the problem has not recurre c (Closed) Unresolved Item 255/87008-06(DRP):
Due to a personnel error, the licensee failed to implement compensatory measures when fire suppression equipment for the IC switchgear room was removed from servic The cover letter for Inspection Report No. 50-255/87008 asked the licensee to address this item in a respons The response was provided on July 3, 1987, and appears to address this issu The inspector notes that this item was identified as Item 03 in Inspection Report No. 50-255/87008; that was a typographical erro The correct number is 0 d (Closed) Unresolved Item 255/87015-02(DRP): The: "Quick-Open" feature of an automatic dump valve was disabled when some links were left open after performing a trouble-shooting activit The inspector reviewed the licensee Internal Corrective Action document and Human Performance Evaluation System Report, both concluded that personnel error and a failure to follow procedures resulted in the link being left ope The reports, and Inspection Report No. 50-255/87015(DRP),
concluded that a safety issue did not exis e (Closed) Open Item 255/87022-0l(DRP):
The preplanning for maintenance work on Diesel Generator 1-1 and Containment Isolation Check Valve CK-CRW-408 did not identify that the equipment would be inoperable, which require an entry into a Limiting Condition for Operation (LCD).
For the Diesel Generator the inoperability was discovered before the LCD time clock expired and for the containment isolation valve the work order was cancelled before disassembly commence The 1 licensee reviewed the work planning process, and determined that the program was acceptable as written and that additional training of the planners and shift supervisors was appropriat *
f (Closed) Open Item 255/87022-02(DRP);
After achieving criticality, the plant was momentarily operated below the minimum Technical Specification temperature limi The event was discussed in LER 255/87028 which was closed in Inspection Report No. 50-255/88010(DRP).
This open item discussed a Technical Specification problem in that a time limit (similar to the one contained in standard Technical Specifications) to return the plant to desired parameters is not provide The licensee recognized the need for the time limit and will include this in the restructured Technical Specification g (Closed) Violation 255/87029-0l(DRP):
Operators failed to implement M0-29 11Engineered Safeguards Lineup 11 as writte M0-29 improperly required a valve to 11open 11 when, in fact, the correct position should be 11 lock closed" which is the position the operator verifie During a nine month period the operators failed to change the procedure to reflect the desired positio The licensee response of July 3, 1987, appears to address the proble h (Closed) Unresolved Items 255/89002-01 and 255/89002-02(DRP):
The Control Room (CR) heating ventilation and air conditioning (HVAC)
system did not meet its design positive pressure while in the emergency mod This was caused by the removal of fire penetration barrier Details of the event and licensee corrective actions ~re discussed in Inspection Reports No. 50-255/88018 and No. 50-255/8900 In addition to the eleven actions enumerated in the latter reports, the NRC was proviJed additional information during the March 7, 1989, Enforcement Conferenc The licensee is incorporating lessons learned ihto the continuing training progra The Safety Evaluation procedure was revised to incorporate guidance on the need to consider the effect of a change on normally non-interrelated system These would include ventilation systems, fire protection, separation, environmental qualification, and securit The Plant Maintenance Procedure FPS-E-1, 11 lnstallation or Repair of Fire Stops and Ventilation Seals on Electrical and Piping Penetrations" was modified regarding HVAC operability requirement The licensee has implemented the design control requirements of 10 CFR 50 Appendix B Criterion III by a series of administrative control Temporary modifications installed for short durations are controlled under Administrative Procedure (AP) 9.31, 11Temporary Modification Control.
The NRC has concluded that the failure to control the temporary modification to the CR HVAC system is a violation of 10 CFR 50 Appendix B, as set forth in the enclosure to the transmittal lette In view of the NRC 1s knowledge of corrective actions taken, no further response is required to this violation (Violation 255/89018-2A(DRP)).
Part bis discussed in Paragraph ** One violation~ and no deviations, unresolved or open items were identifie Operational Safety Verification (71707, 71710, 42700)
Routine facility operating activiti.es were observed as conducted in the plant and from the main control room P1ant startup, steady power operation, plant shutdown, and system(s) lineup and operation were
- observed as alJ-plicable. *
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 verHy 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 General The unit operated at essentially 80 percent power during this reporting perio The 80 percent power limit has been
administratively imposed by the licensee to resolve NRC questions pertaining to steam generator tube leakag The licensee has agreed not to increase power without informing the NRC at least two weeks prior to the increas Personnel Changes The Operations Superintendent (Robert Fenech) resigned on June 23, to become plant manager at a site operated by another utility. A plant employee (Jack Hanson) was promoted tci the Operations Superintendent position effective July Technical Specification Paragraph 6.3.1 and Figure 6.2-2 require that the Operations Superintendent meet the requirements of ANSI N-18.1 (1971) and hold an SRO licens Mr. Hanson currently holds an inactive license for the Palisades Plant and meets or exceeds the plant experience and educational levels of ANSI N-18.1 (1971). Tours The following items were observed during plant tours and were identified to plant personnel for review and resolution if appropriat **
(1) At the entrance to the charging pumps room are two signs that state:
"Emergency Exit Key In Emergency Remove Key From Box To Open Steel Bar Gate
The inspector opened the box located next to each sign and was unable to find a ke The signs appear to be a carry over from a tilTlB when vital area doors were at or near the room entranc The need for the signs was addressed to the property protection superviso (2)
Fire Door 190 going to the C-33/C-40 panels is locked; however, coming from the panels is unlocke It is not clear why the door needs to be locked in -0ne directio This w~s discussed with the operations superintenden (3) A safety locker located on the ground floor of the feedwater purity building has a laminated tag affixed to the door of the locker listing the contents of the locke The inspector observed that an acid suit listed on the tag was missin This was discussed with the plant safety office ( 4)
The door (No. 83) going to the chemistry sample room did not identify that a individual would encounter a contamination area immediately upon entering the roo This resulted in the resident inspector entering a contamination area without wearing proper anticontamination clothin This was identified to the duty radiation protection technicia (5)
Hand Switch HS-1811b, located at remote shutdown Panel C-33, is labeled, 11West Engineered Safeguards Room isolation damper P01811and1813.
It appears that the correct labeling should be 11 *
- P01811 and 181 This was i dent ifi ed to the onshift Shift Enginee d~
Log Review Shift Supervisor log book No. 179, page 96 documented that shortly after placing the SIRW tank on fast recirculation through the spent fuel pool demineralizers the SIRW level slowly started to increas The reason was determined to be a valve (MV-SFP108) that had not been repositioned to closed as required by Step 7.3.1.e.l of SOP 27,
"Fuel Pool System.
The inspector noted that a deviation report was not written and asked the acting operations superintendent if one was appropriat A deviation report was written and processed during the next Corrective Action Review Board (CARB).
The threshold for initiating a deviation report was discussed at the exi **
e.
50.72 Reports On June 27 the licensee made a one hour security notification pertaining to a degraded protective area barrie Apparently the lake water intake crib barrier bars were found to be degraded by ice damag Security compensatory measures were implemented until the identified access way to the protected area via the intake crib could be secure Diesel Generator Fuel Supply On March 3, 1989, the licensee determined that the emergency diesel generator fuel oil supply tank (T-10) was not being maintained at an adequate level to meet the licensee's commitment to maintain a seven day fuel supply on sit This finding was a result of design review done under the Configuration Control Project~
LER 255/89005 was submitted detailing the circumstances surrounding the discovery and planned corrective action On June 20, 1989, the level in T-10 dropped below the interim administrative limit (22,000 versus 23,000 gallons) after the performance of two consecutive operability tests of the diesel generator Apparently, the corrective actions taken after the March discovery were not sufficient to ensure that the administrative limit was not exceeded while the final required value was being determine The surveillance test requires that the diesel be run for a m1n1mum of six hours at full loa Two consecutive tests were conducted in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period prior to June 20, and the level in T-10 was not monitored between tests by persons aware that the current administrative level requirement reflected the design requiremen A Technical Specification C~ange Request has not been submitted, and since current Technical Specifications require only 16,000 gallons (as opposed to 23,000), an update to the previous LER may be submitte No violations, deviations, unresolved or open items were identifie.
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 proper operation of automatic monitoring equipmen Independent surveys were performed in v~rious radiologically controlled area A RP technician found a high radiation door unlocked and unmanne This item appears to be a violation of regulatory requirements and will be followed up in a subsequent NRC inspection (Unresolved item 50-255/89018-03).
- '... *
- 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 iTI accort:laTice with ap~roved procedures~
regulatory guides and industry codes or standards and in conformance with Technical Specification 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 inspector toured containment and found a boric acid leak from a Safety Injection Tank flow transmitter (FT-0308) which had coated a cable tray beneath i The licensee had identified the minor leak on startup in February and had initiated Work Order No. ESS-2490096 It is currently scheduled to be worked during the next cold shutdow At the exit interview the licensee indicated that the effect of boric acid on the cable tray and the cabling has been evaluate The following activities were inspected:
a.
A leaking flange in the fuel oil transfer pump discharge header was replace The inspector found that system cleanliness was not being maintained during the header removal and welding due to failure to cover the pipe end After this was pointed out to the Supervisor the situation was corrected (FOS 24903215). Diesel Generator 1-1 jacket water temperature switch (TS-1481) was high and required calibration (EPS 24903392). Remove/install FT-0315 to establish a temporary sample point per Temporary Modification 89032 (24903180 and 24903432). Install stem and hold down device for MV3234 per Temporary Modification 89031 (24903173 and 24903179). Add Bushing/Retainer Ring to MV 3234 per Temporary Modification 89034 (24903179).
While performing Work Activity 24903179 on June 15, the inspector observed that the doghouse door from the 590 1 level to the east safeguards room was blocked open with welding cables passing through the doo The job supervisor informed the inspector that the control room had been notified that the door was opened and that a door watch had been posted to disconnect the cables if directed by the control roo The inspector asked the shift supervisor if a temporary modification had been processed, as required by Section 17 of Administrative Procedure 4.03, 11 Equipment Control,
11 to block open
that doo The shift supervisor acknowledged that one had not been processed and requested that the work activity be secure Failure to process a temporary modification as required by Section 17.e of Administrative Procedure (AP) 4.03 is a violation of AP 4.0 Compliance to 4.03 is required as outlined in the Notice of Violation (255/89018-2b(DRP). Part 2a is discussed in Paragraph 3.h A couple of days prior to the above violation, the inspector had observed that the door between the east and west safeguards room was allowed to stand open while the west room was cleane During interviews, the inspector was informed that the door mentioned above was opened to allow use of a steam cleaning uni The inspector
'questioned if the doors were being controlled properl To resolve the inspectors questions a deviation report was issue When the deviation report was presented to the Corrective Action Review Board (CARB), the CARB members discussed the fire and flood barrier function of the doo The inspector asked if this door and the hatch to the west room from the component cooling water room also functioned as-a ventilation barrier, since each room has ventilation exhaust/suction dampers that close on high radiation as detected by local room monitor With the door or hatch open the isolation feature of the dampers is essentially defeate Also, the inspector identified that FSAR Table 9-17 (sheets 3 and 4) is misleadin The table lists ventilation dampers and provides the position during various modes of plant operation The table states that the supply/exhaust damper will be closed after a Containment High Pressure (CHP) or Containment High Radiation (CHR) signal. The logic prints show that neither the local monitors or dampers receive a shut signal from CHP or CH This was identified to the system engineer and discussed at the exit intervie The licensee was asked to revise the FSAR, if appropriat One violation and no deviations, unresolved or open_ items were identifie.
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 Limiting 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 M0-7A2 Emergency Diesel Generator 1-2 Surveillance Tes Q0-16 Inservice Test Procedure - Containment Spray Pump *
In addition to obsrving the test, the inspector reviewed the procedure using the FSAR and Technical Specifications as reference document Two questions were identified to the system engineer, who provided acceptable resolutions. The first pertained to Paragraphs 4.3.2, 4.3.3 and 4.3.4. All imply that the lineup established to p*erform the test will make the running pump inoperable. It was unclear why only the running.pump was inoperable, since the test configuration is common to all three pump The engineer provided the inspector with an evaluation (A-PAL-88-040), which explained the flow requirements and the amount of flow available for spray based on the operability of the remaining two pump The second question pertained to _sheet 3 of 3 of FSAR Table 6-1, "Containment Spray System Component Description.
Sheet 3 of 3 discusses the spray nozzles and states that 160 nozzles are installed with a flow of 15.2 gpm per nozzle for a total flow of 2432 gp FSAR Paragraph 6.2.3.2 states that the minimum spray flow required is 2500 gpm, which is within the capability of 2680 gpm that can be provided by two pump Comparing the gpm flow of the nozzle with minimum required flow would imply that the nozzles are under designe The system engineer explained that nozzle flow is a function of pressure drop and at full pressure drop the nozzle flow would exceed 15.2 gpm and provide adequately flo At the exit interview, the inspector asked the licensee to review and revise, if appropriate, Table 6-6 to more accurately reflect gpm flow per nozzl d. Q0-19 RI-81 DW0-1 SH0-1 Inservice Test Procedure - High Pressure Spray Pump Containment Hydrogen Monitoring System Tes (Rod Testing) +Daily Log Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.
Balance of Plant Inspection (71500)
Balance of plant maintenance, modification and management support activities were inspected in conjunction with the review of balance of plant related previous inspection findings discussed elsewhere herein and in NRC Inspection Report Nos. 50-255/89012 and 50-255/89015, including:
maintenance and modification of the electronic and fluid components of the turbine electro-hydraulic control system; addition of temperature control valves to the main generator hydrogen seal oil system; maintenance and modification of turbine turning gear; testing and overhaul of main steam reheater safety valves; modifications to the turbine building sump pumps and piping; and, testing and maintenance of instrument and service air system Completed work orders, facility and specification change (FC and SC)
packages, and completed test procedures were reviewe The activities were conducted in accordance with the licensee's procedures and programs and appeared to be effectively implemente The equipment and systems
- were each. visually inspected during plant walk-downs and the material Londition was found to be goo The inspector also reviewed maintenance records and inspected the physica1 equipment in the.switchyard including the major switches, breakers, and air compressor Prior maintenance, overhaul and repairs to the components appeared to be adequate for their reliable and safe operatio The licensee is planning to overhaul one additional braker {25RB) as soon as it becomes availabl No violations, d~viations, 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 areas, including control and secondary alarm statio 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 A one hour notification pertaining to a degraded protective area barrier is discussed in Paragraph No violations, deviations, unresolved or open items were identified.
1 Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Reports 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 255/89004:
A reactor trip occurred during control rod interlock testing while in hot shutdow The inspector reviewed the operator aid and the revised procedures (R0-21 and RI-47), and concluded that corrective action was taken essentially as reported in the LE (Closed) LER 255/89007:
Power Operated Relief Valves (PORV) left setpoint for Low Temperature Over Pressure (LTOP) protection exceeded the Technical Specification (TS) requirement The licensee discovered that they had inadvertently specified a value for TS 3.1.8.1 that was the nominal settin Therefore, instrument tolerance and drift resulted in the setpoi~t being occasionally above the TS valu The licensee submitted a letter of interpretation explaining that the unusual setpoint methodology meets the intent of the license requirement, and that revised setpoints will be provided when the PORVs are replaced and the variable LTOP modification is made in 1990., This violation meets the conditions of 10 CFR 2 Appendix C Section V.G.l., for not
- issuing a Notice of Violation, as such, a Notice of Violation was not issue A number was assigned for tracking purposes only (255/89018-03). (Closed) LER 255/89008:
Spent fuel pool ventilation system charcoal absorber efficiency was tested August 23, 1988 and did not meet the acceptance criteria, results were not known within 31 days as required, and the inoperability was not recognized by plant management as be;ng reportable to the NR A Qual;ty Assuranc~
audit identified the issue on April 12, 198 Corrective ictions documented in E-PAL-89-018 were reviewed and found satisfactor In accordance with 10 CFR 2 Appendix C Section V.G.l., for not issuing a Notice of Violation, as such, a Notice of Violation was not issue A number was assigned for tracking purposes only (255/89018-04).
Two licensee identified violations for which no Notice of Violation was issued and no deviations, unresolved or open items were identifie.
NRC Generic Letters (92703)
The inspector reviewed the NRC communications listed below and verified that:
the licensee has received the correspondence; the correspondence was reviewed by appropriate management representatives; a written response was submitted if required; and, plant-specific actions were taken as described in the licensee 1 s respons (Closed) Generic Letter 88-03:
Steam Binding of the Auxiliary Feedwater Pump The licensee response of May 9, 1988, has been reviewed and approved by NR NRR acceptance letter is dated May 25, 1988~
No violations, deviations, unresolved or open items were identifie.
Allegation Review (92705, 99014)
(Closed) Allegation RIII-88-A-0112 Concern NRC Region III received an allegation concerning potential falsified resumes and nondestructive examination (NOE) records by individuals employed by Allen Nuclear Associates (ANA).
NRC Review
- on August 19, 1988, the allegation was forwarded to the licensee requesting a review to determine, (1) whether or not employees of Allen Nuclear Associates were using resumes that contained false information pertaining to education and experience, (2) whether or not job completion records involving eddy current testing were falsified, and (3) if in order to meet contractual obligations, individuals with little or no experience were hired by Allen Nuclear Associates and not given adequate trainin A discussion of the investigation and any steps taken to resolve the allegation was also requeste *
The licensee responded by letter dated October 14, 198 The r~sponse discussed the activities and processes implemented when contracting eddy current vendors for examinations at Palisades and described a surveillance of NDE personnel certifications for ANA personnel who participated in eddy current testing of steam generator During this surveillance, only records held by ANA or the licensee were reviewed, no independent verification of education or experience was attempte The results of this surveillance, transmitted in the October 14, 1988 letter, adequately addressed concern three and supported a deteT'Tl1ination that the allegation was not substantiate Lacking any attempts at independent verification, the question of falsified resumes was still unresolved nor did the response address the question of falsified examination record During this time period the plant was encounte~ing difficulties with steam generator tube leakage, and the question of potentially falsified examination records became more significan To resolve this concern prior to the start of eddy current testing, the NRC staff contacted licensee staff by telephone to identify what actions, if any, were necessary to ensure accuracy and veracity of NOE record Licensee staff stated that Palisades Plant personnel conducted 100% oversight of data collection, review, and evaluation of eddy current examination records and were confident that no record falsification had taken plac Region III was aware that similar allegations had been made concerning ANA personnel at San Onofre and Troja Region III obt~ined copies of licensee investigations into these cases, which substantiated falsified resumes by two individuals at each plan These investigations were conducted by contracted investigators and involved independent verification of education and experienc Consumers Power Company supplied a listing of all ANA personnel employed at Palisades and Region III obtained the identities of four individuals whose resumes were inaccurat Two individuals were identified as having worked at Palisade The names were turned over to the licensee who subsequently determined that one was a containment worker and required no certification and the other was a data collector who had been at Palisades on four different occasions, had performed satisfactorily, and had a very fine reputation in the industr The error in his resume involved an overstatement of educational histor Conclusion The licensee investigation showed that ANA employed personnel with appropriate backgrounds and that their training was adequat Concern three is not substantiate The 100% oversight by licensee staff is considered sufficient to ensure that record falsification did not occur, therefore concern two is not substantiate Region III 1 s review identified that two ANA employees with inaccurate resumes worked at Palisades on several occasions, therefore the allegation is substantiate Since the one individual required no certification and the work of the other received 100% oversight, there is no safety significance involve This allegation is close *
1 Branch Chief Routine Plant Inspection (30702)
The Branch Chief, Reactor Projects Branch 2, visited the site on July 19-20, 198 Areas inspected includep East and West Safeguards Rooms, DIG rooms, Service and Fire Water areas, Turbine Building, Control Room, Technical Support Center (TSC), Auxiliary Building, Remote Shutdown Panel, Auxiliary Feedpump Room, Component Cooling Water area, and main charging pump cubicle During the inspections, the inspector noted the 1-2 DIG had several oil leaks which gave the appearance of a lack of routine maintenance and housekeepin Further, an Aeroequip hose fitting appeared loose or improperly connecte While inspecting the East and West Safeguards rooms, it was observed in the East Safeguards room that a loud 11buzzing 11 noise was very distractin When asked about the noise, the licensee was unsure why it existed, but believed it was coming from an electrical component of a radiation monito During the inspection of the West Safeguards room, an overhead blower was actuated and blew directly down in the center of the room with a very high flow rate and no flow diversion for the roo The flow rate was so intense, it was affecting the overhead lighting and likely adding to the spread of radioactive contamination for the roo The room is still contaminated requiring the operators or inspectors to wear protective clothin With the exceptions noted above, the material condition of the plant appeared goo The turbine building was very clean, well lit, and running with no observable steam or condensate leak BOP tagging was observed to be goo The Auxiliary Building contamination clean up was prcgressing well and had shown improvement over the past several year The Control Room (CR) decorum appeared adequate, and CR operators were attentive and professi.ona The plant was operating with a 11 blackboard 11 *
Inspections of the remaining areas (TSC, Service Water Area, etc.) were observed to be generally clean, well lit, and no observable leaks or tagging deficiencie *
At the conclusion of the Branch Chief inspection, the inspector met with the Plant Manager and briefed him of the finding.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviation Unresolved Items disclosed during the inspection are discussed in Paragraph.
Management Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1)
on July 24, 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