IR 05000255/1989027
| ML18054B020 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/19/1989 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18054B019 | List: |
| References | |
| 50-255-89-27, GL-89-07, GL-89-7, NUDOCS 8910020233 | |
| Download: ML18054B020 (9) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/89027(DRP)
Docket No. 50-255 License No. DPR-20 licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 X
Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
July 19 through September 5, 1989 Inspectors:
E. R. Swanson
.
J:;;:l 1L -1-1 Approved Byitt B. L. B~ef
,,. Reactor Projects Section 2A
. Inspection Summary aiok9
~
Inspection on July 19 through September 5, 1989 (Report No. 50-255/89027(DRP))
Areas Inseected: Special unannounced inspection by the resident inspectors of: containment integrity and reportable event No Safety Issues Management System (SIMS) items were close Results:
Of the areas inspected, four apparent violations were identifie These relate to maintaining containment integrity, leak rate testing, corrective actions, and implementation of work control No other Open Items or Unresolved Items were identifie The inspection disclosed weaknesses in the licensee 1 s corrective action and attention to detail concerning prior containment integrity issues. Management review of the actions taken and training of the I&C Technicians and engineers apparently had been inadequate to inform them of the containment integrity concern The inspection noted strengths in the licensee's prompt and well-managed corrective actions taken once the concerns were identified, and the good communications with the NR Q1nn20233 09 091 9
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- DETAILS Persons Contacted Consumers Power Company
- G. B. Slade, Plant General Manager _
- R. D. Orosz, Engineering and Maintenance Manager
~T. C. Watson, ISI/IST Coordinator
- C. S. Kozup, Licensing Engineer
- D. J. Malone, Li~ensing Analyst
- B. P. Benson, Shift Supervisor
- J. L. Hanson, Operations Superintendent 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 September 5, 198 Other members of the Plant staff were also contacted during the inspection perio.
Containment Integrity Event Summary On July 19, 1989, the licensee discovered that containment integrit was not bein~ maintained during the performance of Surveillance Test MI-5 "Containment High Pressure Initiation Circuits for RPS, SIS and CIS 11 and these portions of piping associated with penetrations 17 and 48 had not been leak tested since the penetrations were modified in 198 The discovery was made as a result of air leakage which prevented completion of the MI-5 test. The licensee repaired the leakage and performed leakrate testing of the piping with satisfactory results under Enforcement Discretion granted by R-III on July 20, 198 Event Chronology March 6, 1980 - Consumers Power Company received a Notice of Violation for removing a pipe cap to perform calibration of instruments without leak testing the pipe cap after replacement. This violation concerned containment pressure transmitters and switches associated with penetrations number 17 and 4 April 1980 - Penetrations 17 and 48 were modified by adding additional isolation valves so that the pipe cap is not an isolation-boundary, testability of the isolation valves is improved,
and an isolable test connection is provided for calibration and testin As part of the modification (FC-80-75) jnstallation, six procedures were approve Two of them, which would have tested the entire penetration piping, were cancelled. Records indicate that penetration 48 may have received an appropriate test, but no records of the test were recoverabl Penetration 17 apparently was not tested as require However, calibration of the pressure switches and pressure instruments, performed prior to the 1980 plant startup at 10 and 100 psig, respectively, provides some assurance that the piping integrity was maintaine, 1986, 1988 - Integrated Leakrate Tests (ILRT) were performed; however, most of the pressure switches and instruments associated with penetrations 17 and 48 were isolated and never subjected to ILRT pressure. Local Leakrate Testing (LLRT) did not include testing of certain portions of the modified piping. After this was discovered, these portions were tested on July 20, 1989 and found satisfactory (total of 1,000 cc/min).
July 14, 1989 - During the calibration of pressure instrument PI-1805, the technician disconnected the piping between the
- containment isolation valves and the containment to tie in the pressure source and perform the calibration. Valve MV-1805 was closed for this calibration (see Drawing #2, Penetration 48).
Full calibration pressure could not be reached due to leakage at the pipe-to-valve (MV-1805) connectio The System Engineer and the LLRT Engineer were contacted and recommended tightening the fitting, which had been tested during the last ILRT and apparently was not identified as leaking. These engineers did not consider this to constitute a 11repair 11 under Appendix J since the leakage was already counted in the ILR The technician apparently misunderstood, disassembled additional piping, calibrated the transmitter, and reassembled the piping. A pressure check of the piping indicated the existence of an additional leak from the packing on MV-1805 and a Work Request was initiated by the Operations Departmen The piping was then fully assembled (except as noted below), and MV-1805 was opene It was not identified that this leak affected containment integrity at this tim July 19, 1989 - While conducting a surveillance test (MI-5
"Containment High Pressure Initiation Circuits for RPS, SIS and CIS
) another leak was identified, this time at a fitting near MV-1805 Pressure coold not be increased in the line and the fitting was identified as being "finger tight". This leak was in a portion of the line which might be subjected to containment pressure but is normally isolated by a valve not classified as a containment isolation valve (MV-1805C).
This segment of pipe also had not received routine leakrate testing, nor was it tested after reassembly on July 14 following calibration activitie Th~
calibration activity is the most probable cause of the loose fittin The technicians then stopped the activity, the System
Engineer was notified, and the Shift Supervisor became aware that MV-1805 had a packing leak and that containment integrity was in questio MV-1805 was locked closed to isolate the packing leak from containmen The Plant Review Committee was convened and it was determined that MV-1805 should be classified as a containment isolation valve, which would require an LLRT demonstration test, and that several portions of piping associated with penetrations 17 and 48 must be tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (see below), since they had not been receiving LLRT or ILRT testin July 20, 1989 - Procedures for this testing of penetrations 17 and 48 were developed, reviewed, approved and implemente The licensee interpreted NRC Generic Letter 89-07 to permit 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the testing, but additional time was required for completio The NRC Region III Administrator granted an additional 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by Enforcement Discretion on July 20, 1989 (subsequently documented by correspondence dated July 21 5 1989), to permit the completion of testing without shutting down as the Technical Specifications would have otherwise require Event Evaluation (1) Technical Specification (TS) 3.6 requires that containment integrity be maintained when the plant is above the cold shutdown conditio TS 1.4 defines containment integrity as having all manual containment isolation valves close Performance of MI-5, during monthly testing while operating between April 1980 and July 19, 1989, required the opening of one manual containment isolation valve and then cycling the other containment isolation valves open for penetrations 17 and 48 during about a thirty minute period for each penetratio (Valves MV-18148 or MV-18158 were opened for about thirty minutes while the next isolation valve in the lines toward containment were cycled open and close.) Likewise, performance of the annual calibration of the pressure transmitters 1805, 1805A, 1815, 1812, 1812A and 1814 in the time frame subsequent to 1980, resulted in about nine apparent violations of the requirements of TS 3.6. The piping was typically disassembled to hook up test instrumentation for the calibrations without being tested prior to returning it to service at the completion of the test. While the repairs were being made to the valve fitting on July 14, 1989, the line was disassembled with the non-certified isolation valve (MV-1805) closed for about six hours. This time period exceeds the time allowed to commence action to shut down the plant under Technical Specification *
3.0.3. The fitting which was found to be loose on July 19 was apparently left in that condition after the July 14, 1989 calibration and posed a potential leak pathwa However, valves which were similar in design to the designated c~ntainment isolation valves were closed during testing and operation to isolate the piping from containmen. I
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Although the test MI-5 was aborted on July 19, 1989, the revision of the procedure was prepared, reviewed, approved and executed within the time requirements of the Technical Specification During the period of July 14 to July 19, 1989~ *a containment boundary leak (packing on MV-1805) was all_owed to exist without action taken to quantify the leakage or promptly repair the valve (Work Order #24903923 is in a "planning hold" status).
This condition was known by both the I&C Technician and the Operations personnel who initiated the Work Reques An evaluation of the significance of the leak apparently was not mad These conditions constitute an apparent violation of TS 3.6 and 3.0.3 (255/89027-01).
- i (2)
From 1980 until 1989, 10 CFR 50 Appendix J, Section III testing requirements for LLRT and ILRT were not met for portions of piping associated with penetrations 17 and 48, in that they did
- not receive preoperational and periodic leakage rate test Similarly, post modification testing requirements specified by 10 CFR 50 Appendix B Criterion XI "Test Controls" were not fully implemented, in that portions of the modification did not receive preoperational or operational tests to demonstrate the acceptability of the design and construction. These constitute apparent violations of license requirements (255/89027-02).
(3)
10 CFR 50 Appendix B, Criterion XVI "Corrective Action" requires measures to be taken to assure that causal factors are identified and taken to preclude repetitio Similar events have occurred in the past at Palisade In 1980, containment integrity testing after removal and replacement of a pipe cap was the subject of a Notice of Violation from the NR It was this latter violation which resulted in the current penetrations 17 and 48 configuratio In 1983, (LER 83060) a pipe cap was removed during an outage by construction personnel, which violated containment integrity requirement In 1985, (LER 85029) two containment isolation valves in series were found to have excessive leakage and action was not promptly taken to correct the situatio Corrective action for this event included hanging orange tags oti each containment penetration isolation valve, and training to heighten personnel awareness of containment integrity requirement Maintenance was done on the lines by taking apart fittings to repair leakage without identifying as-found leakage. This is identical to the concern expressed in Paragraph 6 of NRC Inspection Report 255/89003. Corrective action taken apparently was not effectiv The common cause in these events appears to be a lack of adequate training for plant personne I&C Technicians apparently had no understanding of
- containment integrity concern This history of ineffective corrective action is an apparent violation of license requirements (255/89027-03).
(4)
The disassembly and repair of the fitting leak was done without proper authorization and work controls required by Palisades Administrative Procedure 5.01 "Processing Work Requests/Work Orders". This constitutes an apparent violation of Technical Specification 6.8.1 which requires implementation of procedures to control maintenance activities (255/89027-04). Corrective Actions (1)
Procedure Revisions Surveillance procedures were revised to provide an alternate means of testing the circuitry without the use of the pressure switches, and the calibrations were rescheduled for periods when containment integrity is not require Procedures were developed and implemented to perform LLRT of the previously untested portion (2) A review of ILRT/LLRT program will walkdown all penetrations and review past penetration modifications to ensure proper testing of all line (3) A new TS amendment concerning containment integrity will be reviewed with applicable procedures to ensure compliance is maintaine (4) Training for appropriate engineering and I&C technicians will be updated as necessar Four apparent violations and no deviations, unresolved or open items were identifie.
Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Report (LER) by means of direct observation, discussions with licensee personnel, and review of record The review addressed compliance to reporting requirements and that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/89016:
Untested piping associated with the containment boundar The event is discussed in Paragraph 2. A decision on enforcement action will be forthcoming~
No violations, deviations, unresolved or open items were identified *
- 4~
Management Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1)
on September 5, 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 or processes as proprietary.
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