IR 05000255/1990012

Insp Rept 50-255/90-12 on 900309-0419.Violations Noted. Major Areas Inspected:Actions Previously Identified,Plant Operations,Radiological Controls,Maint,Surveillance,Steam Generator Replacement,Fire Protection & Reportable Events

ML18057A226
Person / Time
Site:	Palisades
Issue date:	05/09/1990
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18054B597	List: IR 05000255/1990012 ML18054B596 ML18057A225
References
50-255-90-12, TAC-45156, NUDOCS 9005160267
Download: ML18057A226 (16)

Text

U. S. NUCLEAR REGULATORY COMMISSION REGION II I Report No. 50-255/90012(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:

March 9 through April 19, 1990 Inspectors:

E. R. Swanson Approved J. K. Heller J. F. Schapker

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By:_µ,..Bruce L. Burgess, Chief._,-

Reactor Projects Section 2A

~~ection Summary License No. DPR-20 C.~-C/-'JC

!fate Inspection on March 9 through April 19, 1990 (Report No. 50-255/90012(DRP))

Areas Inspected:

Routine unannounced inspection by the resident inspectors of: actions on previously identified items; plant operations; radiological controls; maintenance; surveillance; steam generator replacement; fire protection; reportable events; and, NRC Headquarters request Safety Issues Management System (SIMS) Item TMI II.F.24 (TAC 45156) was reviewed and close Results:

Of the nine areas inspected, no violations or deviations were identified in seven area Two violations were identified (one for inappropriate temporary procedure change use in Paragraph 2.c, one for repeated minor fire protection violations in Paragraph 8) in the remaining area The inspection disclosed weaknesses in the licensee's fire protection program implementation and procedure change proces The inspection noted strengths in the licensee's predictive trending of Safety Injection Tank leakage; prompt identification and response to an increase in primary coolant leakage; improvements in dosimetry; and the comprehensiveness of the corrective actions to the temporary procedure change issu New Open Items were identified (and are discussed in Paragraphs 3.a, and 5.a) in the areas of: monitoring of potentially contaminated water and control of vendor informatio ;* C) () 5 J.,*::11:) ~2 ~'.'.' 7_

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• DETAILS Persons Contacted Consumers Power Company

• G. R. D. R. K. *J. R. *K. R. L. *C. J. *R. s. R. W. K. L. D. *J. Slade, Plant General Manager Rice, Plant Operations Manager VandeWalle, Technical Director Orosz, Engineering and Maintenance Manager Haas, Radiological Services Manager Hanson, Operations Superintendent Kasper, Mechanical Maintenance Superintendent Osborne, System Engineering Superintendent Brzezinski, I&C Engineering and Maintenance Superintendent Kenaga, Health Physics Superintendent Kozup, Technical Engineer Brunet, Licensing Analyst Mccaleb, Site Quality Assurance Director Wawro, Operations Scheduling Supervisor Frigo, Operations Staff Support Supervisor Roberts, Plant Projects Supervisor Toner, Plant Projects Superintendent Phillips, Senior Systems Engineer Turner, Electrical Maintenance Superintendent Schepers, Site Quality Assurance Administrator Nuclear Regulatory Commissio.n (NRC)

• E. R. Swanson, Senior Resident Inspector

• J. K. Heller, Resident Inspector J. F. Schapker, Reactor Inspector (DRS)

• Denotes some of those present at the Exit Interview on April 19, 199 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) (Closed) Open Item 255/89021-0l(DRP)):

Licensee communication of evolved changes in t~Configuration Control Project (CCP) were not communicated effectively to the NR The scope of the CCP was reviewed with the changes highlighted at a meeting in the NRC Region III offices on January 11, 1990, and also outlined in the licensee's January 23, 1990 letter. Further inspection of the CCP process and progress is documented in Inspection Report

• No. 50-255/90010(DRS).

2 (Closed) Unresolved Item 255/89029-0l(DRP)):

Implementation of the Fire Protection Progra This Unresolved Item identified several minor examples of fire protection program violation The

• licensee's corrective actions appear to address the identified problems, however, during this inspection period additional problems were identified and are discussed in Paragraph (Closed) Potential Violation 255/89033 Paragra hs 2.c and 3.a(2)):

A change o. intent was made by Tempera ry Change Notice TCN to an operating procedure, and a Safety Evaluation was not conducted of the hydrostatic test of the PORVs and Block valve The identification of the concern over TCN usage was identified by the NRC during post event review as being a probable root cause for not providing more rigorous review of the planned test metho With regard to TCN usage the licensee evaluated their use of a TCN in this situation, concluded that existing procedural controls were misleading; formally revised the particular operating procedure to reflect the appropriate valve lineup steps; demonstrated the revised procedure; and plans to revise the existing administrative controls to require formal review and procedure revision before valve lineup changes are made in the futur As interim measures, Senior Reactor Operators (who must approve TCNs) have been briefed on the lessons learned from this event, and all TCNs must be reviewed by the Operations Superintenden Further action was being taken to evaluate whether the Primary Coolant System hydrostatic test should be an attachment to Standard Operating Procedure SOP-1 11 Primary Coolant System 11 or a special test for future performance Additional action was being taken to ensure that a more rigorous safety evaluation was performed for each TCN instead of a simple determination being made that an unreviewed safety question does not exis The second potential violation dealt with a concern for not doing a safety evaluation of the apparent 11 special test".

As stated above, the licensee has not yet concluded that a special test is the appropriate vehicle for the performance of this tes As noted in Inspection Report No. 50-255/89033, it is not conclusive that this failure to perform additional review of the test method would have identified the susceptibility of.the PORV to pop open, but the additional review may have raised the questio In view of the above corrective actions, a no response violation was issued for this item (255/90012-0l(DRP)).

One violations with no response required and no deviations, unresolved or open items were identifie.

Operational Safety Verification (71707, 71710, 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:

Reactor Operators; Senior Reactor Operators; Shift Technical Advisors; and, Auxiliary Equipment Operators were observed and evaluate Included in the review was 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 General The plant began the reporting period at 80 percent power, and was removed from service on April 16 to begin a 30 day preplanned maintenance outag The scope of the outage included, steam generator replacement engineering activities, safety related restraint reverification, PASM modifications, installations of motor disconnects for off-site power modifications, cooling tower modifications, safety injection tank check valve repair, and complete open outage related work request Tours (1)

During a tour of the turbine building on March 27, the inspector observed a pump and hose set up to remove ground water from the electrical pit, adjacent to the lC switch gear panel, to a turbine building drai The inspector questioned the set up since the pit has labeling indicating internal radiological contamination affixed to the pit cover The turbine building drain was in a clean area. The inspector discussed this with operations and radiological control personnel who indicated that the turbine building sump was a monitored release path and historically contamination levels in the pit were lo Samples were taken of the pit after approximately 100 gallons had been pumpe The water had a greater radioactive concentration than expecte The water in the pit and sump were then pumped to the radiological waste system for processin The licensee documented the situation on Radiological Incident Report Number 90-01 A copy of Report 90-010 was sent to Region III for review by a radiation specialist. This was documented as an Open Item until a Region III radiation specialist evaluates the licensee actions (Open Item 255/90012-02(DRS)).

(2)

During a tour of the screen house, the inspector noted that piping for a newly added flow meter (FE-5360), for the 11A

cooling tower, was vibrating excessivel During a subsequent tour and pr~or to discussion with plant management, the inspector observed that a temporary restraining device was installed and a work order initiate (3)

While touring the station battery areas, a white substance was identified floating on the surface of the batteries. The vendor (C&D) reported that it is a collection of minute glass fiber fragments from the cell mat, and that the condition was cosmetic onl (4)

A lack of restraint of several components (breaker removal stand, vacuum cleaner) in the cable spreading room was identifie To address the concern for these objects becoming missiles or interfering with breaker/equipment operability during a seismic event, the licensee is pursuing corrective action involving appropriate restraint Primary Coolant Leakrate On April 11, the licensee determined that an unidentified primary cool~nt leakrate had exceeded the 1 GPM Technical Specification limit for a 36 minute period, due to a leaking filter in the letdown lin Based on Volume Control Tank (VCT) level change the leakage was initially estimated at 7-9 GP Subsequent review of graphs from the Critical Function Monitor, estimated the leakage at approximately 12 GPM. Jime did not permit nor was it practical to perform the proceduralized leakrate calculatio Once the leak source was identified, letdown was secured, the filter isolated, letdown reestablished and a three hour primary coolant system leakrate was performe The results indicated 0 GPM leakag The inspector discussed the Technical Specifications, Emergency Plan and reportability requirements with the licensee (Shift Engineer, Technical Engineer and Operations Scheduling Supervisor) and determined that the licensee:

had not exceeded a Technical Specification; had not entered the Emergency Plan; and, had not exceeded the reportability threshol The licensee 1 s identification and prompt action reflect exemplary attention to detail in plant operatio Auto-Start of the 11A 11 Auxiliary Feedwater Pump On March 22 the licensee notified the NRC, pursuant to 10 CFR 50.72(b)(2)(ii), -Of an auto-start of the 11A 11 auxiliary feedwater pum The pump started at 9:11 a.m., as the result of a personnel error during restoration steps of surveillance test MI-39, "Auxiliary Feedwater Actuation System Logic Test

• It appears that test personnel performed the last two steps out-of-sequence, such that, a block was removed without resetting a standing auto-start signa Due to a standing alarm from the

testing, the pump start was not annunciated, such that, the only indications of pump operation was a control switch light change (green to red) and flow indication on the vertical control room pane Because of this, the pump ran and injected water for 21 minutes before discover The inspector discussed the event with the crew involved and will revisit this item when the Licensee Event Report is issue The inspector noted, during review of the paperwork associated with this event, that the person making the offsite NRC notifications was not a licensee operator and in fact was an auxiliary operator. This was discussed with the shift engineer who stated that auxiliary operators are trained as communicators during Emergency Plan trainin The inspector did not identify problems with the communications, however, noted that other utilities have had problems when 10 CFR 50.72 notifications were made by those who do not understand the event they were reporting (reference Information Notice 85-80, "Timely Declaration Of An Emergency Class Implementation Of An Emergency Plan, And Emergency Notifications").

This was discussed with the Operations Superintendent who stated that auxiliary operators are 11 in training" as communicators with the intent that -they will man the communication lines when continuous communications with the NRC are require This will free the shift engineer from the phones and per~it him to function as the shift technical adviso Currently the auxiliary operators are performing on-the-job training by making the 10 CFR 50.72 notifications under the direction of t~e Shift Enginee SafetL.!:njectio!! Tanks During a review of the control room logs, the inspector noted that the 11A 11 Safety Injection Tank sampling frequency had been decreased from 30 days to two day This was discussed with the Operations Scheduling Supervisor who provided the inspector with graphs predicting the inleakage rates and expected dilution rates of the tan The supervisor was able to identify which primary coolant system check valve was leaking and discussed which instruments would indicate if the "Event V 11 check valves started leakin The inspector concluded that the licensee actions are sufficiently predictive to prevent entry into an LCO due to high level or low boron concentrcttion in the tan The licensee determined that the repair of primary coolant system check valve (CK-ES3101) would be performed during the current 30 day maintenance outag The inspector discussed the repair with the Operations Scheduling Supervisor since Primary Coolant System water level would be lowered to half loop operation to facilitate repair The supervisor indicated that the check valve bonnet can be removed and temporary plugs installed while the water level was at 1/2 loop operations without interrupting shutdown cooling flo If the temporary plugs (which can withstand a water pressure of 22 inches)

fail then water level would stabilize at the half level and not flow out the check valv~ opening or interrupt shutdown coolin *

• Plant Shutdown During the April 16 shutdown the inspector observed the following activities:

(1)

Removal from service the 11A 11 main feedwater pump (SOP-12)

(2)

Transfer of 4160V buses 11A

,

118

,

11 E

, &

11 F 11 from station power to startup transformers (SOP-30)

(3)

Opening of the PORV isolation valves (SOP-1)

(4)

Movement of heavy loads (Equipment hatch concrete blocks) in the Spent Fuel Pool area (FHS-M-23)

(5)

Placing Shutdown Cooling in Service (SOP-1) System Walkdown The inspector verified operability of the 1-1 Diesel Generator by verifying system alignment using the applicable portions of Revision 17 to Checklist *22.1, 11Diesel Generator System Checklist."

No items were found that degraded the system, however, the following minor items were identified:

(1)

ME-DE 661, 11 Prelube Pump Discharge PS-1477 Isolation Valve" is identified as a lock open manual valv The inspector found the valve open but not-locked:

(2)

A number of drain lihes were found with a cap installed, however, the valve lineup sheet did not require verification of the ca (3)

MV-DE 515, "Day Tank T-25A Drain" has a two quart bucket attached to the valve to catch fuel oil leakag The bucket was approximately 1/8 ful At the inspector 1s request the licensee reviewed the leakage and initiated a work reques Items 1 and 2 were discussed with the Operations Superintendent who indicated similar checklist problems were addressed on an open deviation repor These items should be resolved when the deviation report is close Drawing Control Drawing control was reviewed after it was identified that a drawing was missing from the site aperture card files but was in the controlled hard copy drawing Licensee considers the aperture card file an informational file that, although updated along with controlled files, was not maintained with 11 red-lining 11 suitable for engineering or critical plant use The Palisades site has upgraded their aperture files by annotating the cards when modifications/revisions are in

progres In this way the user would know whether he needs to seek a controlled copy or no Aperture card files are maintained in the site document control, the Technical Support Center and the Emergency Operations Facility. It was also determined that the Engineering Records Center in Jackson, Michigan, produces drawing revisions to P&IDs in less than 30 day Eight sets of controlled drawings are available on sit *

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 various radiologically controlled area On March 26 and 27, the resident inspector was informed of walkouts by the International Brotherhood of Electrical Workers (IBEW)

contract radiological services technician This was discussed with the Radiological Service Manager who stated that eight contractor radiological services technicians from General Technical Services were on site; none participated in the walkou This subject was revisited on April 10, ~nd the Radiological Service Manager indicated that the majority (46 out of 48) of the contract radiological services technicians scheduled for the April 16 maintenance outage were onsit Indications are that the IBEW does not plan additional walkouts at this tim A change in primary dosimetry was made effective April 1, 1990, which r~placed the film badge with a Panasonic Thermo-luminescent devic The inspector was briefed on the licensee's plans to replace their secondary dosimetry and self readers with state-of-the-art solid state, multi-function, alarming dosimeters on June 1, 199 This action is expected to greatly improve exposure contra The new epoxy flooring is essentially complete in the Auxiliary Building and facilitates spill cleanup and decontaminatio One drawback is that water on the high gloss floor is hard to se Several individuals received shoe contamination on April 11 when a flange in the letdown system leake No violations, deviations, unresolved or open items were identified.

• 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 Specification The following items were considered during this review:

the Limiting Conditions for Operation were met while compon~nts or systems were removed from service; approvals were obtained pr-ior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl The following activities were inspected: Shutdown Cooling Heat Exchanger Isolation valve SV-3223A had an air leak (Work Order (W.O.) 24001715).

Step 4 of the work order stated 11 *** install a rebuilt kit in SV-3223A, refer to ASCO Bulletin NP8316...

The work order package contained NP8316, with portions of the installation instructions highlighte The inspector found that NP8316 was not controlled per Palisades Nuclear Plant Administrative Procedure 10.45, "Vendor Manual Control."

Paragraphs 6.2 and 6.3 of Procedure 10.45 provided specific steps pertaining to review, approval and identification of vendor manual Paragraph 4.0 of Procedure 10.45 defines vendor manual as "technical information supplied by equipment manufacturers that addresses installations... of equipment."

NP8316 appears to fit this definitio The inspector discussed this with the electrical superintendent who indicated that the instructions received with the parts were not controlled and it has not been the plant practice, nor was it intended, to control the instructio However, when the work order was written and issued, personnel reviewed the instruction to determine the applicable step This was evidenced by the highlighting of the vendor instruction The inspector reviewed the licensee response dated May 15, 1985, to the vendor interface Paragraphs (2.1 and 2.2) of Generic Letter 83-28, "Salem Anticipated Transients Without Scram." This response implied that all vendor information will be processed and controlled by an administrative procedure to assure it was complete and up-to-date. Attached to the response was a copy of Administrative Procedure 10.4 At the exit interview the licensee was asked to review this item and the response to Generic Letter 83-28, to determine if their current program and practice meet the intent of the program submitted to the NRC (Open Item 255/89012-03(DRP)).

• During this inspection period several wiring-related issues have been identified by the licensee, for which corrective actions are being take The licensee had indicated that the modification process will be revised to include wire verification point to point in the installation procedur Further improvement in scoping the post modification testing process is also underwa One example is covered under D-Pal-90-034 and -053 where a wiring error was made while installing alternate power capability for the P-55C charging pum The wiring to the alternate power supply indicator light in the control room was not properly wired, and this feature was not checked by post-modification testing. Subsequent operation identified the indicator light inoperability. This feature was repaired and tested. Subsequent to this activity, the P-55C pump failed to start on a low pressurizer level as designe Investigation determined

.

that a wire was lifted during the previous corrective action, which was not relande Workers had failed to document and verify the lifted wire as required by the Work Order and as performed for other wire Testing following the correction of this error was thorough in testing all starting, indication and trip circuits associated with the pum Diesel Generator 1-2 was removed from service the week of April 2, 1990, to perform various preventive and corrective maintenance activities (W.O.s 24000997, 24001050, 24905609).

Subsequent testing of the diesel generator reflected two recurring problems had not been solve First, that one (of the two normally in service)

air start motor did not start the diesel in less than 10 seconds; and the replacement lube oil pump did not correct the low oil pressure condition that had been previously note These issues, along with other non-disabling outstanding diesel generator action items, were reviewed with the System Engineer to ensure his knowledge of the conditions and identify the planned action The inspector also reviewed the operability testing trends to ensure that all apparent adverse conditions are being addresse One generic concern for the diesel is the survivability of instrumentation on the diese Numerous instruments have failed repeatedly due to vibration and the current plan is to substitute more environmentally suited instrumentatio The licensee was encouraged to reevaluate their priorities concerning this wor In general, the diesel generators have been very reliable from a starting on demand perspectiv Historically, hours in the LCD are high because the licensee uses the LCO time limit to perform preventive maintenance on-lin W.O. 2400986, "Replace recorder FR-0701/0702 per SC 89-293 11 W.O. 2402168,

"Repack CV-05228 with live load packing" 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 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: M0-7A-l and 2 Diesel Generator Operability Test MR-6 Area Monitor Operational Check PPAC 236 Control Rod Exercising DW0-1 Daily Control Room Surveillanc SH0-1 Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.

Steam Generator Replacement (73753) The inspector observed the base line eddy current examination that was performed by the licensee with contracted services from Allen Nuclear Associates (ANA).

Eddy current examination was performed using Zetec MIZ 18 data acquisition with bobbin, 8xl, and motorized rotating pancake coils (MRPC).

A 100 percent steam generator tubes examination was performed using bobbin coil, supplemented with a random sample of 8xl coil examination The MRPC was utilized to evaluate any distorted indicat'ions detected with bobbin or 8x In addition, visual inspections were performed to evaluate indications which were accessibl The licensee identified distorted indications with the bobbin coi These indications were located approximately four to six inches from the tube sheet fac Visual examinations confirmed that the eddy current indications were due to weld spatter adherence to the tube internal diamete The eddy current signal response was indicative of the visually observed inner diameter distortio Eddy current data identified 12 tubes which were not expanded and two that were over expanded during fabricatio The licensee has contacted the vendor for disposition of the improperly expanded tube In addition, permeability indications were found in various 1l *

tube locations. These indications will be reinspected with a magnetically biased probe upon completion of the current bobbin examinatio The inspector will review the disposition of the tube expansion problem and the permeability indications during a future inspectio The inspector observed:

the installation of the tube sheet templates; cleanliness control; ET data collection, management, and analyses; and reviewed the following procedures:

Procedure N Title Revision Date NDT-G-06 Installation of Tube Sheet

03/29/90 Templates - Palisades Steam Generators NDT-ET-17 Eddy Current Examination -

03/29/90 Motorized Rotating Pancake Coil (MRPC)

NDT-ET-18 Eddy Current Examination -

03/29/90 MIZ-18 Pull Through Techniques EM-09-11 Palisades Eddy Current Procedure 0 03/30/90 for Data Management for the Replacement Steam Generators ECT-SG-1 Inservice Inspection Steam

03/28/90 Generator Plan Inspection SQAP-041 Palisades Eddy Current

03/31/90 Examination for the Replacement Steam Generators Eddy current inspector qualification records and certifications complied with SNT-TC-lA requirement Review of ET equipment certifications and calibrations complied with ASME Section XI, Article IV, 1983 Edition, 1983 Addend The licensee's baseline eddy current program exceeds the ASME Section XI Code and Technical Specification requirements and provides a good basis for future eddy current examinations of the steam generator The inspector toured the new steam generator laydown are Workers were in the primary side hot leg bowls and the secondary side steam separator/dryer area of both steam generator The inspector observed that tools were taken into the secondary side without any provisions for tool accountabilit The inspector discussed this item with the steam generator rep la cement project manager who stated that the vendor will perform an inspection (via a remote controlled robot and camera) once the steam generators are uprighted *

• The inspector reviewed the licensee evaluation of Information Notice 88-06, 11 Foreign Objects In Steam Generators

• This notice stated that Catawba 2 experienced a loss of steam generator tube wall thickness because of foreign objects left in the top works of the steam generators that were washed down to the tube sheet during the first fuel cycl The licensee evaluation and inspections addressed the installed steam generators and not the new ones, because replacement was not planned at the time of the information notic The licensee was asked if the planned pre-service inspection would address the problems identified in Information Notice 88-0 This was discussed with steam generator project personnel and at the exit intervie Recently the inspector learned that another utility had developed a method to wash down the steam generators tubes by use of a modified sludge lanc This resulted in dislodging previously unidentified foreign material. This information was discussed at the exit interview and the staff indicated that they-were aware of this through EPRI communication No violation, deviations, unresolved or open items were identifie.

Fire Protection (71707, 64704)

Fire protection program activities, including fire prevention and other activities associated with maintaining capability for early detection and suppression of postulated fires, were examine Plant cleanliness, with a focus on control of combustibl~s and on maintaining continuous ready access to fire fighting equipment and materials, was included in the items evaluate On March 22 the inspector opened a flammable storage loCker located near the countin~ room, at the north end of the controlled corridor on the 611 elevation of the Auxiliary Buildin Within the locker were a number of Class 1 flammable liquids, that were in the original vendor 1 s containers versus safety cans equipped with flame arresters and spring activated caps, as required by Paragraph 6.3.3.b of Palisades Nuclear Plant Fire Protection Implementing Procedure FPIP-7 11 Fire Prevention Activities

• In addition, on April 17 a five gallon can (without a flame arrester and spring cap) of Class 1 solvent (thinner) was used during floor coating activities in the 1-2 Diesel Generator roo Compliance to FPIP-7 is a requirement of Technical Specification 6.8. Failure to implement FPIP-7, as stated above, is a violation of Technical Specification 6.8.1.f (255/90012-04(DRP)).

Both of the above items were discussed with the Fire Protection coordinator who determined that the amount of the Class 1 liquid did not create a safety or fire hazar Based on this information the inspector would consider this a violatior with minor safety impact and not pursue enforcement actio However, sine~ October 6, 1989, these are the third and fo~rth examples of noncompliance with FPIP-7 that the inspector has

• identified to the licensee without effective corrective actions being take Therefore enforcement action is considered appropriat The other two examples were addressed in Paragraph 7 of Inspection Report No. 50-255/89029 (Unresolved Item 255/89029-0l(DRP)).

In addition, the licensee's audit organization has identified and documented examples of compliance problems with FPIP-The amount of liquids in the storage locker consisted of:

0

5 - one liter plastic bottles of ethyl alcohol 2 - one quart glass bottles of Morpholine 4 - one gallon glass bottles of Propanol All of the bottles were 1/2 to 7/8 full, which indicated that personnel would obtain new bottles from the store room versus use or dispose of leftover quantitie Based on the amount of Class 1 liquids in the storage locker it would appear that the licensee was not implementing the spirit of Paragraph 6.3.3.a to FPIP-Paragraph 6.3.3.a states that

"storage of flammable/combustible liquids should always be maintained at the lowest practical quantity.

One violation and no d~viations, unresolved or open items were identifie Safety Assessment/Quality Verification (35502, 40500)

The effectiveness of management controls, verification and oversight activities, in the conduct of jobs observed during this inspection, was evaluate The inspector frequently attended management and supervisory meetings involving plant status and plans and focusing on proper co-ordination among Department The results of licensee auditing and corrective action programs were routinely monitorea by bttendance at Corrective Action Review Board (CARB) meetings and by review of Deviation Reports, Event Reports, Radiological Incident Reports, and security incident report As applicable, corrective action program documents were forwarded to NRC Region III technical specialists for information and possible followup evaluatio 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 accomplished.

• \\

• (Closed) LER 255/86022:

Overstressed High Pressure Safety Injection P1p1ng using ex1st1ng FSAR response spectra. The licensee considers that updating their FSAR to refl~ct implementation of ASME Code Case N-411 (Alternative Dumping Values for Seismic Analysis of Classes 1, 2, and 3 Piping Systems).

This issue was reviewed by the NRC in Inspection Report No. 50-255/89024 and will be reviewed during closeout of the Notice Of Violation issued concerning seismic analysis issue * (Closed) LER 255/89023 Revision 1:

IE Bulletin 79-14 discrepancie As of the submittal date of the LER, only one hanger (U-bolt)

assembly exceeded the FSAR allowables and interim operability criteria detailed in the licensee 1s letter dated November 2, 198 Further followup will be conducted by Region III, DRS of the licensee 1 s resolution to their IEB 79-14 reverification effor (Closed) LER 255/89025:

Power Operated Relief Valve (PORV) opening, zero-power reactor trip and Safety Injection Actuation. This event was reviewed in Inspection Report No. 50-255/89033 and the adequacy of the licensee 1 s numerous corrective actions and test program are being evaluated by NR Additional issues raised in the above referenced report are discussed in Paragraph 2.c of this repor (Closed) LER 89-TS2:

Channel Failure of the Reactor Vessel Level Monitoring System (RVLMS).

The licensee 1s action plan for restoring operability was reviewed and found satisfactor (Closed) LER 255/90002:

Reactor trip caused by cooldown during power reduction after feedwater pump trip. Three equipment failures precipitated or contributed to the reactor trip. First the feedpump trip, for which a definitive cause has not been identified, may have been caused by intermittent diodes in the feedpump vibration alarm circuit interacting with the thrust trip circuit. These diodes were replace Second, the 11 C 11 charging pump failed to start on lo\\rl pressurizer level due to an error in maintenance work practices where a lead was lifted and not relande Adequate work controls existed but were not implemented by the work cre The licensee discussed this item with the workers involve Third, the Control Room annunciator chime bell failed intermittently. A faulty solenoid coil was replaced. These latter two failures both distracted the operator and failed to alert him that a pre-trip was reached on the Thermal Margin Monito The inspector reviewed the corrective actions and found them adequat No violations, deviations, unresolved or open items were identifie.

Region and Headquarters Requests (255065)

(Closed) TMI Item II.F.2.4 (SIMS TAC 45156):

Installation of the Reactor Vess~eve 1 Monitoring System ( RVLMS).

The system was i nsta 11 ed during the 1988 refueling outage, and, as requested by the NRC Safety Evaluation dated January 12, 1987, the licensee submitted an implementation letter on January 9, 198 In this letter the licensee identified that one point of eight on one channel failed shortly after testin **

Subsequently, one other point on this channel failed and another was declared inoperable due to low oLj_tpu The entire other channel was declared inoperable due to the heater circuit failur As required by the Technical Specifications, a special report (89-TS2) was submitted to the NRC on October 23, 1989 describing the circumstances and outlining their plans to replace the failed sensor channel probe during the 1990 refueling outage, and two of the three failed sensors on the other channe The inspector witnessed portions of the installation under FC-567 and the preoperational testing; verified that approprfate changes were made to operating procedures (EOPs and SOP-1), that operator training was conducted, that the system engineer was aware of system deficiencies and had planned corrective action, and that bi-weekly and refueling outage testing (D/W-01, RI-113) is planned and conducte A comment was made at the exit meeting regarding the operators' mistrust of the new system, largely as a result of its current state of operabilit No violations, deviations, unresolved or open items were identifie.

Q~n Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot Open Items disclosed during the inspection are discussed in Paragraphs 3.b.1 and.

Management Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

on April 19, 1990 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 J 6