IR 05000255/1990014
| ML18155A276 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/14/1990 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18155A277 | List: |
| References | |
| NUDOCS 9006210379 | |
| Download: ML18155A276 (18) | |
Text
Docket No. 50-255 Consumers Power Company ATTN:
David P. Hoffman Vice President Nuclear Operations
- 1945 West Parna 11 Road Jackson, MI 49201 Gentlemen:
'"nm 1 4 1s90 This refers to the routine safety inspection conducted by Messr E. R. Swanson, J. K. Heller and T. J. Kobetz during the period of April 20 through rtiay 31, 1990, of activities at the Palisades Nuclear Generating Plant authorized by NRC Provisionctl Operating License No. DPR-20 and to the-discussion of our findings with Mr. G. B. Slade and others of your staff at the conclusion of the inspectio The enclosed copy of our inspection report identifies areas examined during the inspectio Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne No violations of NRC requirements were identified during the course of this inspectio In accordance with 10 CFR 2.790 of the Commission 1 s regulations, a copy of this letter, the enclosed inspection report and your response will be placed in the NRC Public Document Roo We will gladly discuss any questions you have concerning this inspectio
Enclosure:
Inspection Report
No. 50-255/90014(DRP)
See Attached Distribution
RII I
Schweibinz/dp
Sincerely,
Brent Clayton, Chief
Reactor Projects Branch 2
RI II (Zc
Clayton
(//'0D
r*~--
,
Consumers Power Company
Distribution
REGION I I I
F.acility Narrie:
Palisades Nuclear Generating Plant*
Inspection At:
Palisades Site, Covert, MI
Inspection' Conducted: April 20 through May 31
Inspectors:
E. R. Swanson
Approved
J.. K. Heller
T. J. Kobetz
~.
By:. B. L. Burg~ief
Reactor Projects Section 2 DAT License No. DPR-20
- Inspection Summary
Ins~ection on Apri 1 20 through May 31, 1990
(Report No. 50-255/90014
(DR ))
.
.
Areas Inspected:
Routine unannounced inspectibn by the resident inspectors
of: actions on previously identified items; plant oper~tions; maintenance;
.
surveillance; security; reportable events; bulletins and generic letters; CFR 21 report; and, NRC Regional.& Headquarters requests. Safety Issues
.
Management System (SIMS) item TI 2515/103 (TAC 6'9761) was reviewed and remains
ope.
Results: Of the ten areas inspected, two licensee identified violations were
identified in Paragraph 8, and were found to meet the crite~ia of 10 CFR 2
Appendix C for non-i~suance of a citatio The i~spection disclosed weaknesses i~ the licensee's late identification of
the heat trace problem reported in LER 255/9000 The inspection noted strengths in the lic~nsee's responsiveness to plant
operattonal needs during startup, th~ identification of a potential protected
area breach, the comprehensive actions on the PART 21 issue, and their efforts
to define the goal of "TOP TEN
11 for employees~
No new Open Items and/or Unresolved Items were.identifie DETAILS Persons Contacted
Consumers Power Company
- G. B. Slade, Plant General Manager
- R. M. Rice, Plant Operations Manager
- D. J. VandeWalle, Technical Director
- R. D. Orosz, Engineering and Maintenance Manager
- K. M. Haas, Radiological Services Manager
J. L. Hanson, Operations Superintendent
R. B. Kasper, Mechanical Maintenance Superintendent
K. E. Osborne, System Engineering Superintendent
R. M. Brzezinski, I&C Engineering and Maintenance Superintendent
L. J. Kenaga, Health Physics Superintendent
- R. E. McCaleb, Director of Quality Assurance
- C. S. Kozup, Technical Engineer
J. R. 'Brunet, Licensing Analyst
R. J. Frigo, Operations Staff Support Supervisor
K. A. Toner, Plant Projects Superintendent
- Denotes some of thdse present at the Management Interview on June 1,
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) Mr. D. Danielson, Chief, Material and Processes Section, documented
in a memorandum that Region III has reviewed the Palisades Open Item
list and determined that the items listed below can be closed
because they are duplicative of issues addressed in Generic Letter 89-10,
11Safety-Related Motor-Operated Valve Testing and
Survei llance
11 and Bulletin 85-03,
11Motor Operated Valve Common Mode
Failures During Plant Transients Due To Improper Switch Settings
,
supplement on Generic Letter 89-10 and Bulletin 85-03, supplement
one open at the Palisades Station and will be inspected at a later
dat (1)
(Closed) Open Item 255/87028-01:
Need clarification for
Bulletin 85-03 response concerning use of data base formulated
from their own testing. *
(2)
(Closed) Open Item 255/87028-02:
No test data was available to
assure adequacy of the limitorque open torque switch settin (3)
(Closed) Open Item 255/87028-03:
No documented program or test
data was available to assure adequacy of the limitorque close
torque switch settin (4)
(Closed) Open Item 255/87028-04:
Long term valve operability
program needs development by the license **
{5)
(Closed) Bulletin 87-28:
Entry was in erro Bulletin 87-28
does not ex i_s (Closed) Open Item 255/88026-01:
Spurious opening of Auxiliary
Feedwater (AFW) flow control valves, flow instability on AFW pump
P-8 The spurious opening of CV-0727 and CV-0749 has been noted to
occur during initial testing after maintenance on the syste The
licensee has postulated that air collects on top of the "balanced
plug" design, and when pressure builds up at the valves when a pump
first starts, that they open, and then pressure equalizes and the
valves close. This initial transient phenomena has been mitigated
by venting, and has only occurred during initial testin Venting
is controlled by Standard Operating Procedure SOP-12 "Feedwater System", Attachment In regard to the second issue of AFW pump P-8C instability on
recirculation flow, the pump was disassembled in November 1989 and
found tu have some pitting on the impelle Although acceptable,
the impeller was replaced and the bulk of testing is now performed
with flow (not on recirculation).
Long term plans are to install a
manual bypass line for testin (Closed) Open Item 255/89021-02:
Nuclear Safety Services Department
(NSSD) involvement in the review of audit plans and participation in
audits did not appear adequat NSSD staff involvement in audits
was planned and documented in the October 20, 1989, NSSD staff
meetin Inspector review indicated that ~he plan was being
implemented adequatel (Open) Violation 255/89024-01 (Example A.2.):
Pipe Support JB-14-6
"f-1197.4 and JB..:.14-6 "H197.5).
The licensee response dated April
12, 1990, stated on page 8 of attachment 1 that the stress package
for these supports was currently in final review and will be
complete by April 30, 199 On May 2, 1990, the li_censee informed
the resident inspector that the package was not complete and, in
fact, was not in final revie It appears that the priorities of
the responsible group in the Corporate Office were modified without
knowledge of the commitmen The inspector requested that the
licensee inform the responsible DRS section chief that the
commitment was not met and provide a written revision to reflect the
corrected completion dat At the exit interview the potential
consequences of providing false information was discusse No violations, 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 roo Plant startup, steady power
operation, pJant shutdown, and system lineups and operation were observed
as applica_ble.
The performance of licensed Reactor Operators and Senior Reactor
Operators, and Shift Engineers, 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 to _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 Periodic verification of Engineered Safety Features status was conducted
by the resident inspecto Equipment alignment was verified against
plant pro~edures and drawings and detailed walk downs selectively
verified: equipment labeling, the absence of leaks, housekeeping, freeze
protection, calibration dates, operability of support systems, breaker
and switch alignment as appropriat~. Walkdowns during this inspection
period focused on the shutdown cooling syste General
The unit began the reporting period in a preplanned maintenance
outage and was returned to service on May 1 During the outage the
licensee performed: steam generator replacement engineering
activities; safety related restraint reverifications.; Post Accident
Sampling System modifications; installation of motor operated
disconnects for off-site power modifications; cooling tower
modifications; Auxiliary Feedwater Turbine driven pump overhaul;
repair to the leaking Safety Injection Tank outlet check valve; and
completed numerous open outage work order Before the turbine was put on line, four unexplained atmospheric
steam dump openings occurred, two of them causing actuation of the
auxiliary feedwater (AFVJ) syste The AFW actuations were
explained to be a result of the pressure transient causing the AFW
actuation channels (which are very quick acting) to sense a spurious
low steam generator level, depending on the initial steam generator
leve The root cause for the atmo~pheric steam dump openings was
determined to be electronic noise on the temperature circuit which
inputs to the steam dump controlle The noise source has not been
specifically identified, but circuit modifications have been made to
reduce the nois Current limiting capacitors were added and a fast
acting current switch was rep-laced with a similar, but slower
devic A final calibration check was performed on the circuits and
a demonstration test was satisfactorily performed to confirm the
adequacy of the circuit modification A LER is planned by the
license CFR 50.72 Reports
( 1)
On April 25, the licensee informed the NRC that a Local
Leakrate Test (LLRT) of containment penetration 26 determined
that leakage limits exceeded allowable Technical Specification
limits. It was determined that a containment nitrogen supply
line check valve would not close because of machining marks on
the piston. After resurfacing, a LLRT was performed
satisfactory and the penetration returned to service. Generic
implications of the failure were considered and the licensee
concluded that further immediate action was not warrante Additional NRC review will be performed during close out of the
associated LE (2)
On April 25 the licensee informed the NRC that the analysis for
a main steam line break transient described in their FSAR was
not limiting for containment pressur In their original
analysis they had analyzed for a guillotine-type steam line
break as the bounding case for peak containment pressur Feedwater isolation currently occurs on a low steam generator
pressur A followup analysis was performed on a small break
which would allow a slower blowdown_ of the faulted steam
generato This resulted in a delayed isolation of the
feedwater which would allow more steam to be released into
containment for a longer period of time, resulting in a higher
peak containment pressure than previously analyze The peak
pressures analyzed exceeded the containment design pressure of
55 psig by approximately 20 psi This pressure does not
exceed the capability of the containment, how.eve The identification of this oversjght was a result of analytical
work being performed for the upcoming steam generator
replacemen Since the results were determined to have an
immediate operational safety impact, the licensee modified the
feedwater isolation actuation circuitry to include input from
containment high pressur Additional NRC review will be performed during close out of the
associated LE (3)
On April 25 the licensee informed the NRC of gross deformation
of pipe supports (H-747, 765) associated with two of the four
Safety Injection Tank outlet line The two hangers'
supporting "I" beams had buckled and the riser clamps were
ben Calculations performed by the licensee's vendor
regarding operability of the hangers in the as-found
configuration supported the conclusion that the supports were
"'capable of carrying the imposed design loads and qualified for
the operability criteria" (Interim Operability Criteria).
The
calculation evaluated the "worst case" loads including dead,
thermal, and Safe Shutdown Earthquake load The hangers were
repaire..
The remaining two (H-735, 756) were inspected on April 26 and
found to have sli~ht deformation that didn't require repai A region III structural specialist reviewed the licensee repair
activities and calculatio The inspection results will be
documented in Inspection Report No. 50-255/90015(DRP).
(4)
On May 5 the licensee informed the NRC that a LLRT of
containment penetration 49 indicated that leakage limits
exceeded the allowable Technical Specification limit Additional _review determined that only administrative limit was
exceede Based on this information the 50.72 notification was
retracted and no LER will be issue The inspector reviewed
the associated work request, retest of penetration 49 and the
DR associated with the test failur The inspector does not
have additional questions at this tim Oe_erational Readiness of the Spent Fuel Pool Crane
The inspector received a telephone inquiry from an individual who
had concerns about operational readiness of the spent fuel pool crane
and the integrity of the container vans used to transport material
to/from the corttainment equipment hatc This inquiry was discussed
with Region III and the on-shift outage manage It appears that the crane was very 'noisy while moving or lifting a
load and had control problem In addition, the container vans were
rusty on the botto The outage manager ~tated that: crane control problems were
experienced at the beginning of the outage but were resolved by
replacing control circuit cards; the crane was noisy, however, the
noise was characteristic of the crane and did not indicate an
operational problem; and, the integrity of the safety brakes was
satisfactory. The contractor who owned the vans, Bechtel, was asked
to confirm the integrity of the container van The inspector observed several lifts/movements of container vans and
did not notice any unusual noises or control problem The
inspector interviewed a crane operator who stated that control
problems have not reappeared si~ce the circuit cards were replace The inspector also interviewed the area coordinator who stated that
he had observed a number of 1 if ts and had not noticed any unusua 1
noise During one lift, the Bechtel engineer performed an
inspection of the container van botto The inspection did not
identify any problem Subsequently, the inspector contacted the
individual who initiated the inquiry and the concerns were
resolved.
- Plant Startup
During the May 17, 18 and 19 startup the inspector observed the
fo 11 owing:
(1)
Portions of the plant heatup from cold shutdown to hot ~hutdowri
(GOP 2).
(2)
Portions of the mode change from hot shutdown to hot standby
(GOP 3).
(3)
Control rod withdrawal (SOP 6)
(4)
Inverse multiplication plot (GOP 3, attachment 2).
(5)
Licensee response to potential control rod group sequencing
problem caused by a faulty control rod position car (6)
Operations management routinely visited the control roo (7)
Support from other plant departments was available when
required and promptly supplied when requeste Isotopic Analysis for Iodine of the Primary Coolant
On May 20, 1990, a required isotopic analysis.for iodine of the
primary coolant was not completed within the specified two to six
hour time perio Reactor power was increased from 3.3 percent to
23.6 percent in an hour which exceeds the 15 percent change which
invokes the sampling requirement under Technical Specification
4. Samples analyzed before the power increase and the following
day indicated normal levels of iodine, and the licensee concluded
that the event had no safety significanc The air ejector off
gas monitor was monitored periodically during the startup and would
have given an indication of any unusual increase in iodine level A Human Performance Evaluation.will be conducted by the license Further review of this event will be done after the LER is submitted
to the NR No violations, deviations, unresolved or open items were identifie.
Maintenance (62703, 42700)-
Maintenance activities in the plant were routinely inspected, including
both corrective 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 i11 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
components or systems were removed from service; approvals were obtained
prior to initiating the work; activities were accomplished using approved
procedures; and post maintenance testing was performed as applicabl The following activities were inspected: Boric Acid Pipe Heater Circuit 4358 Failure (Work Order (WO)
24001878).
Initially, this work request was written to resolve a
circuit failure alarm believed caused by a loose fuse holde The
Work Order instructions stated troubleshoot, repair, and adjust as
necessary for proper operatio During the troubleshooting, the
inoperability of circuit 4358 was discovere The inspector noted
that an inherent weakness exists with instructions that state
"troubleshoot, repair and adjust as necessary for proper operation."
In this case no limitations or precautions were included pe~taining
to LCO time limit Which may have contributed to the licensee
exceeding an LC Paragraph 8.g of the report discusses the
enforcement aspect of this work activit Modification of the fuel oil pump suction and discharge piping to
repair fuel oil leaks (WO 24001300).
This modification required the
installation and welding of additional piping and flange The
welders were interviewed to determine _if they were cognizant of weld
buildup requirement The welders interviewed were able to discuss
a recent problem that resulted from insufficient weld buildup and
the corrective action implemente Installation of fasteners for the Auxiliary Feedwater pump equipment
hatches (WO 24906149).
This work order required the drilling of
holes in the floor to facilitate the installation of anchor The
inspector found that the workers understood the restrictions
pertaining to cutting of rebar and appeared to properly use
equipment that would prevent cutting of reba VOTES testing on PORV block valves M0-1042A and -1043A (WO 2400709,
2400711). Check valve CK 3101 *resurfacing of seat (WO 24903760,
RWP 900419).
..
No violations, 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 or reviewed: RI-3
High Pressurizer Channel Calibratio DW-13
Local Leak Rate Test for Inner and Outer Personnel Air
Lock Door Seal Q0-18
Inservice Test Procedure - Concentrated Boric Acid
Pump R0-32-49
Local Leak test for penetration 4 S0-48
Escape lock penetration tes T-232
Nitrogen Backup Supply Test for Auxiliary Feedwater
System (performed November 88). DW0-1
Daily Control Room Surveillanc SH0-1
Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.
Security (71707) Routine facility security measures, including control of access for
vehicles, packages and personnel, were observe Performance of
dedicate.d physica 1 security equipment was verified during inspections in
various plant area The activities of the professional security rorce
in maintaining faciTity security protection were occasionally examined or
reviewed, and interviews were occasionally conducted with security force
member During tours of the plant the inspector observed that contractor personnel
challenged visitors and their escorts when it appeared that a security
violation was about-to occu This was highlighted in the exit meeting
as a strength of their security training progra The licensee reported that the underwater integrity of the m1xrng basin
may have been compromised by a shifting sand bar and natural wave actio The method of discovery is significant in that plant personnel noted
large fish in the mixing basin and pursued their method of ingres The
discovery, repair and reporting were prompt and professional, indicating
a good knowledge of unique plant design feature No violations, deviations, unresolved or open items were identifie Safety Jl.ssessment/Qua l ity Verif i ca ti on ( 35502, 40500)
The effectiveness of management controls, verification and oversight
activities, in the conduct of jobs observed during this inspection, was
evaluated.
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 monitored by attendance 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 in.formation and possible followup
evaluatio As part of the licensee
1 s efforts to communicate expectations to
employees, the licensee is using their "Weekly Bulletin
11 to describe the
characteristics of a
11Top Ten" performing plant. Four indicators were
chosen to measure overall plant performanc These are:
(1) reliability
(measured by capacity factor), (2) regulatory performance (measured by
violation points and SALP ratings), (3) ALARA (measured by radiation
exposure), and (4) cost effectiveness (measured by generation cost).
No violations, deviations, unresolved or open items were identifie.
Reportable Events (92700, 92720)
The inspector reviewed the following Licerisee Event Reports (LERs) by
means of direct observation, discussions with licensee personnel, and
review of record The review addressed compliance to reporting
requirements and, as applicable, that immediate corrective action and
appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/89006-Revision 1: Component cooling water
availability following a high energy line brea (Closed) LER 255/89009: Loose valve operator stem coupling results
in inoperable containment isolation valv (Closed) LER 255/89021: Single failure potential within CR HVAC
circuitr (Closed) LER 255/89021 Revision 1: Single failure potential within
CR HVAC circuitr (Closed) LER 255/89TS1 (255/8999-LL): Radiation monitor inoperable
for greater than seven day (Closed) LER 255/90003: Inadvertent auxiliary feedwater actuation
during logic testin The inspector reviewed the revised procedures
and licensee training program and concluded the corrective action
was taken as stated in the LER.
- (Closed) LER 255/90004: Failed heater cable results in inoperability
of a concentrated Boric Acid Heat Trace Channel for a period greater
than allowed by Technical Specification Initially, it was
believed that a fuse holder was the problem that caused a circuit
failur However, during the maintenance activity the inoperability
of circuit 4358 was identified. A time line of the repair is
provided below:
3/29/90 - Secondary heat trace channel TICA-4358 was found ope This is the first indication that the heat trace was
inoperabl The time was not documented on the Work Order
log sheet. A check of the security logs for auxiliary
building entries shows that the individual identified on
the work request made three entries between 8:30 p.m. and
Midnigh /30/90 - 1:00 The Deviation Report identifies that
the need to replace secondary heat trace channel
TICA-4358 was discussed at the daily maintenance
meetin /31/90 - 11:17 The heat circuit was declared
inoperable and the plant entered a LCO, requiring
the plant be in hot shutdown within the next 36
hours if the circuit was not returned to servic :44 The heat trace circuit was repaired
and the plant exited the LC The licensee concluded that the inoperability determination should
have been made at 1:00 p.m. on April 3 Using this time the
licensee complied with the LCO time limi However, sufficient
information was available on March 29, 1990 at midnight, to
determine that the equipment was inoperabl Using this time the
licensee did not comply with the LCO time limi The inspector
reviewed this item to determine if enforcement action was
appropriate using March 29, 1990 (midnight) as the time of
inoperabilit If this time is used, then the licensee exceeded the
LCO time limi This would be a less significant vio*lation of a
Technical Specification and categorized as a Severity IV or V
violatio CFR Part 2, Appendix C.V.G. states that the NRC may
refrain from issuing Notices of Violation that: were identified by
the licensee; can be classified as a Severity Level IV or V
violation; was reported; was not a willful violation; and will be
corrected; including measures to prevent recurrence, within a
reasonable period of tim Based on this, e~forcement action was
not appropriate. (Closed Violation (NV6) 255/90014-0l(DRP)) (Closed) LER 255/90005:
Inoperability of Auxiliary Feedwater (AFW)
System as the r~su1t of a valving error during restoration of the
Backup Nitrogen System fol lowing bottle replacemen ** *
The valves that supply steam to the Turbine Driven AFW Pump and the
valves that regulate AFW to both steam generators are air operated
valve The principle air source is instrument air (regulated at
80-100 psi) and the backup is compressed air (nitrogen) supplied by
two manifold The compressed air is regulated at 60 ps Installation of the manifold was discussed in NRR Safety Evaluation
dated May 26, 1983, to address alternate safe shutdown capability,
sections III.G.3. and III.1 of Appendix R to 10 CFR 5 In that
Safety Evaluation the licensee committed to provide a standby 12
hour source of compressed gas to pperate certain critical valve During auxiliary operator training, the licensee found bottles to
each manifold valved out-of-service. Since the Technical
Specifications do not specifically address either the instrument air
or compressed air systems, the licensee requires operability of both
and considers loss of either air supply cause for entry into the
Limiting Condition for Operatio Upon discovery of the valving
errors the licensee evaluated operability and determined that the
manifold for the AFW flow control valves was operable, with one of
four bottles valved out-of-servic The licensee determined that
the manifold for the steam supply valves to the turbine driven AFW
pump was inoperable with four of eight bottles valved out-of-service
because, under worst case conditions the compressed gas was only
available for six hours versus the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> identified in the Safety
Evaluatio The iicensee has determined that the valving error was the result of
personnel error during changeout of empty bottles. Corrective
action, in the form of instruction on bottle replacement (formally
considered skill-of-the-craft) including valve verification upon
restoration and modification of system checklist to include the
valves that were operated, has been implemente The inspector has reviewed the enforcement policy and determined
that this LER identifies a deviation from a commitment which fits
the severity level IV or V categor In addition this LER was
evaluated for enforcement action and the determination made that
enforcement action was not necessary because the provisions of
Appendix 10 CFR 2. Appendix C, V.G,
11 Exercise Enforcement
Discretion
11 were me These provisions include the following
criteria. It was: identified and reported by the licensee;
corrected in a reasonable period of time; not a willful violation;
and, classified as a severity level IV violatio (Closed Violation
(NV6) 255/90014-02(DRP))
Two licensee identified violations and no deviations, unresolved or open
items were identifie NRC Compliance Bulletins (92703)
The inspector reviewed the NRC communications listed below and verified
that: the licensee has received the correspondence; the correspondence
was revie0ed by appropriate management representatives; a written
response was submitted if required; and, plant-specific actions were
taken as described iri the licensee's respons *
(Open)Bulletin 89-03 (255/89003-BB):
Potential Loss of Required
Shutdown Margin During-Refueling Operation The licensee responded to
the Bulletin on November 21, 1989, outlining their intended actions prior
to refueling in the fall of 199 The NRC acknowledged their response by
letter dated May 10, 1990, and requested written confirmation of
completion of the action No violations, deviations, unresolved or open items were identifie.
NRC Generic Letter (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 88-11 (255J88011-GL):
NRC Position on Radiation
Embrittlen1ent of Reactor Vessel Materials and it
1 s Impact on Plant
Operation The licensee responded by letter dated November 21, 198 In this letter, they predicted that use of Regulatory Guide 1.99 Revision
2 methodology for determining when Palisades would exceed 10 CFR.50.61
screening criteria, would result in exceeding this criteria iri 199 The
licensee implemented the revised methodology which was reviewed and
approved by the NRC, as part of Technical Specification Amendment Number
13 No violations, deviations, unresolved or open items were identifie.
10 CFR 21 Report (36100, 92701)
Consumers Power received notification of potential misapplication and
improper installation of Patel/EGS conduit seals through notification
from the vendor and by NRC Information Notice 90-2 The licensee
reviewed all four modification pack~ges where Patel conduit seals had
been used and verified either by physical verification or record review
that appropriately sized grommets had been used for each applicatio In
one case, the vendor specified wire size tolerance was.002 inches
smaller than acceptable for the grommet use Wire from the same spool
was found to be of an acceptable diameter but to make sure, the licensee
~1ill physically verify the wire size during the next outag The second issue raised was the possible loosening of the union nuts due
to inadequate torquin The licensee checked about 35 percent of the
seals and found all of them properly torque No further action on this
is planne This issue is closed for Palisades (Part 21
255/90014-03(DRP)).
1 Inspection of Regional and Headquarters Requests (255103/TAC #69761)
(Open) Temporary Instruction (TI) 2515/103 - Loss of Decay Heat Removal (Generic
Letter No. 88-17) Programmed Enhancements Revie An inspection of the
subject matter was performed to verify the licensee preparation for
non-power operation in accordance with the long term actions of Generic
Letter 88-1 Provisions described in Consumers Power Company letter
. dated January 31, 1989 were reviewe NRC has not yet completed its
Safety Evaluation Report of the six programmed enhancements described in
the licensee's letter, and therefore, this inspection cannot be
complete Instrumentation
In addition to the existing loop level instrument, a new independent
level instrument will be installed during the 1990 refueling outag This instrument will have a range span of 100 percent of the loop 2
hot le The licensee intends to continue using the installed sight
glass for once per shift calibration check Qualified core exit
thermocoupl~s (CETs) will continue to be relied upon for temperature
measurement while the reactor vessel head is installed. These can
be read from several different sources (plant computer, critical
function monitor, or cooling instrumentation).
While the head is
off, loop RTDs can be used, but due to location they are not
expected to be useful for other than trending purpose No plant
procedures exist governing the use of RTOs in this condition. Alarm
capability for increasing temperature while on shutdown cooling has
not been provide Monitoring of the shutdown cooling (SOC) system
performance is provided by flow indications (both total and
individual loop), a trend recording of the temperature outlet and
return to the primary coolant system, pump breaker indication and a
pump trip alar An alarm is also provided on low pump discharge
pressure of about 80 percent of normal flo The viability of this
alarm in monitoring pump performance has been demonstrated during
prior events and is considered by the licensee to be equivalent to
pump motor amp trending or acoustical monitorin Trending of the
SOC parameters is provided only for temperatur Level trending has
been added to the plants Critical Function Monitor (CFM) during the
last few outages, but no procedural requirement for the capability
exist The future loop level instrument will have a permanently
assigned data point on the CF Procedures
Procedures have been developed to govern operation of the NSSS,
containment and supporting systems for reduced i,riventory coo 1 i n General Operating Procedure (GOP) 14 "Shutdown Cooling (SOC)
Operations", Standard Operating Procedure (SOP) 3 "Safety Injection*
arid Shutdown Cooling", and Off Normal Procedure (ONP) 17 "Loss of
Shutdown Cooling" contain adequate instructions to govern the
operation of the SOC system during normal and off normal conditions
including loss of flow, cooling, or coolant inventor The GOP,
SOP, and ONP do not reference the Emergency Operating Procedures
(EOPs) if significant core damage is expected or indicate However, operator training and the symptom based EOPs provide
adequate confidence that mitigating actions (such as containment
hydrogen control) will be carried out.
- Containment closure provisions are contained in GOP-14 with
Operations normally responsible for clearing lines from the
equipment hatch and Maintenance responsible for positioning the
hatch and installing/tightening four clamp Four bolts maintain
the hatch adequately sealed to permit any containment pressure to
further seat the hatc GOP-14 also contains pretautions meeting
the intent of the guidance for avoidance of perturbations while in a
reduced inventory conditio Equipment
In addition to proceduralized equipment operability requirements,
the licensee has developed an excellent method of keeping the
control room operators informed of equipment availability and their
preferential us The Operations Scheduling Supervisor (an SRO)
prepares a status sheet with limits for each plant parameter while
on shutdown cooling reflecting: primary coolant system (PCS) state
of fi 11, S/G tubes covered or not, temperature and' level bands
(assumed in containment closure response time calculation),
operability of core cooling paths, inventory addition paths,
electric power requirements, preferred core exit thermocouples,
level instruments, and Containment Status, closure time and
res pons i bi 1 i t ONP-17 contains three methods for core cooling when the PCS
integrity is not maintaine In order of preference, containment
spray pumps, Spent Fuel Pool Cooling, and PCS boil off and makeup
methods are outlined. A HPSI pump may be used under the provisions
of 10 CFR 50.54(X).
Flow paths have been evaluated and tested as
necessar Adequacy of vent paths for cooling flow have been
evaluated when necessar Reliable communication methods have been
provided for the conduct of activities under accident condition Analyses
The inspector verified that analyses exist to support the procedures
including the PCS vent sizin Technical Specifications
The licensee submitted a Technical Specification Change Request on
June 28, 198 NRR has not completed their action on the amendmen PCS Perturbations
The inspector verified the adequacy of the 12 month training
provided to operators, procedures and controls concerning PCS
perturbations. Additional precautions are required to be considered
for both monitoring and preventing a loss of shutdown cooling during
activities of jeopard No violations, deviations, unresolved or open items were identified.
.,.
1 Management Interview (30703)
Th~ inspectors met with licensee representatives (denoted in Paragraph 1)
on June 1, 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