IR 05000255/1990018
| ML18057A474 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/13/1990 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A472 | List: |
| References | |
| 50-255-90-18, NUDOCS 9009240143 | |
| Download: ML18057A474 (13) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/90018(DRP)
Docket No. 50-255 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 License No. DPR-20 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
PaJisades Site, Covert, MI Inspection Conducted:
July 17 through August 27, 1990 Inspectors:
E. R. Swanson J. K. Heller Approved 6y:
2A Inspection Summar Inspection on July 17 through August 27, 1990 (Re~ort No. 50-255/90018 (DRP))
Areas I~ected: Routine unannounced inspectiony the resident inspectors of:
actions on-previously identified items; operations safety verification; maintenance; surveillance; fire protection; security; reportable events; allegations; and, design change No Safety Issues Management System (SIMS)
items were reviewe Results: Of the nine areas inspected, no violations or deviations were identified in eight areas. One violation was identified (failure to submit a Technical Specification Change Request) in the remaining are The weaknesses and strengths disclosed in this report are discussed in paragraph 13 "Exit Interview."
New Open Items were identified (and discussed in Paragraphs 3.c, 3.e, 6.b, and 10.a.(2)) in the areas of: safety injection tank level float calibration, spe~t fuel pool leakage, heat trace circuit overheated, and application of an SER for a modification not specifically addressed in the SER *
OOQ9?4014~ 900914
~6R.-AfiocR 05000255 Q
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 K. E. Osborne, System Engineering Superintendent L. J. Kenaga,. Hea 1th Physics Superintendent
- J. L. Kuemin, Licensing J. R. Brunet, Licensing Analyst
- W. L. Roberts, Senior Licensing Analyst
- R. J. Poche, Licensing Engineer Nuclear Regulatory Commission (NRC)
E. R. Swanson, Senior Resident Inspector
- J. K. Heller, Resident Inspector
- Denotes some of those present at the Exit Interview on August 29, 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 255/88018-02(DRP):
During performance of a Hot Leg-InJect1on flowpath test tRU=65), some performance problems were noted with three check valve The problems were documented on D-PAL-88-106 and resolved by modifications made per Specification Change 88-25 (Closed) Open. Item 255/89028-0l(DRP):
Consumers Power Company commitment to prepare a fina1 report of the Augmented Test Program was reviewe A final report was issued on June 30, 1990, which describes the status and documents the closeout o"f the 1986 Augmented Test Program by factoring its elements into the System Functional Evaluation Augmented Test Program (which is controlled by Administrative Procedure 9.27).
The inspector also reviewed the closure status of the QA Surveillance (D-QP-89-002) which covered the Augmented Test Program and determined that the outstanding actions have been complete No violations, deviations, unresolved or open items were identifie '* Q£erational Safety Verification (71707, 71710, 42700)
Routine facility operating activities were observea-as conducted in the plant and from the main control roo Plant startup, steady power operation, plant shutdown, and system(s) lineup and operation were observed as applicabl The performance of: Reactor Operators and Senior Reactor Operators, Shift Engineers, and Auxiliary Equipment Operators was 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 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 operated at essentially 80 percent power during the report perio Plant Tours (1)
During backshift tours performed approximately a week apart, the inspector heard electronic dosimeters (one per tour) alarming in the whole body count roo The dosimeters were in the room because of calibration problem The dosimeter will alarm (beep) when exposed to a pre-programmed radiation dose or if the memory has not been 11 dumped 11 to the access control computer within a preset period of time; for both examples the later was true. During the second tour, a security officer asked if the dosimeter was alarming because a source was exposed..
Surveys confirmed that a source was not exposed. *There appears that a potential exists for negative training because personnel may become accustomed to the false alarm and not respond appropriately when the alarm is valid. This.was discussed with Health Physic (2) During this period, a number of inspectors from Region III and Washington toured the assessable areas of the plant and stated that it appears the licensee has expended a lot of effort to establish and maintain a high cleanliness standar (3)
The inspector found emergency lighting unit #89 lit for no apparent reason and powered by its internal power supply,
(4)
while the normal power supply was intact. This was identified to the shift enginee Investigation determined that an internal circuit card had malfunctioned; the card was replace Periodic verification of Engineered Safety Features status was conducted. Walk downs of the Auxiliary Feedwater System verified: the absence of leaks; operability of support systems; and that assessable breaker and valve alignment was appropriate for major flowpath valve Safety Injection Tank Level Float Calibration During a control room tour, the inspector observed that one of four safety injection tank level instruments was indicating low level and in alar The required shift readings, per Technical Specifications Table 4.1.2 (Item 13), were annotated that the tank remained operable because the level float was not in alar The floats are set at the Technical Specification limit. The licensee has trends of containment temperature versus safety injection tank level that indicate the safety injection tank level instrument will fluctuate*
with a change in containment temperatur The insp~ctor ask~d the I&C department how the level float was calibrated since the licensee uses the float as the mechanism to confirm compliance with the level requirements of Technical Specification 3.3.1. The I&C department stated that a calibration has not been performe The licensee appears to be in a "Catch 22
, in that, the level instruments identified in the Technical Specification are known to be unreliable and the floats used to confirm the safety injection tank level are not calibrated. The licensee was asked if the float setting versus known level could be confirmed during the next refueling outage. This is an Open Item pending the licensee revie (Open Item 255-90018-0l(DRP)) Technical Specification 3.2 InterEretatio~
The licensee discussed Technical Specification 3.2, "Chemical and Volume Control System" with the resident inspector approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the following was implemente After discussion with NRR and Region III, the licensee was informed that the NRC has no problems with actions implemente Concentrated boric acid pump P-56A had developed a small leak that did not render the pump inoperable, but would require removal of heat trace insulation for the pump and associated piping to facilitate preplanning of the repair during the next outag The licensee intended to declare the flow path associated with the pump inoperable and enter a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LC * However, it is unclear if the Technical Specification associated with the heat tracing can be interpreted as either path related or circuit relate Removal of the insulation would make a subcircuit of each heat trace channel inoperable, resulting in a shutdown per the time limits of Technical Specification 3. if the Technical Specification is circuit relate In this case, the licensee considers the Technical Specification to be heat tracing path related because the inoperable heat tracing is unique to.P-56A and is not common to the other flow path The licensee recognizes that if subcircuits to a common flow path were declared inoperable then the more restrictive LCO would appl In addition, the licensee recognizes that Technical Specification 3.2 can be interpreted a number of ways and should be revise As a result, the licensee is preparing a Technical Specification change reques Spent Fuel Pool Leakage On July 6 the spent fuel pool gate developed a significant leak due to insufficient nitrogen pressure to the inflatable seal This resulted in a spent fuel pool level reduction of approximately 6 fee The water drained into the fuel tilt pit/transfer tub The fuel tilt pit was isolated from the transfer tube by a normally***
closed isolation valv The leakage stopped when the water level equalized between the tilt pit and the spent fuel poo The water level was returned to the desired level by increasing the water in the tilt pit and the spent fuel pool simultaneously. During this event spent fuel pool cooling was secured when the water level fell below the suction lines. While spent pool cooling was secured the licensee continuously monitored the temperature of the spent fuel poo At the time of this the report, the licensee evaluation (Deviation Report D-PAL-90-193) had not been complete The inspector will revisit this item when the Deviation Report is complete. This is an open item pending the inspector review (Open Item 255/90018-02(DRP)).
Two open items and no violations, deviations, or unresolved items were identifie.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repairs) and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl The focus of the inspection was to assure the maintenance activities reviewed were conducted in accordance with approved procedures, reg~latory guides and industry codes or standards and in conformance with Technical Specifications. The following items were considered during this review:
the Limiting Conditions for Operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl ~--------------------------------------
The following. activities were inspected: Replace Garlock Expansion Joi"nts on EOG 1-1 (W.O. 24004262). Replace Seal-Tite Conduit on Air Start Solenoid for EOG 1-1 (W.O. 24003586). Calibrate Lube Oil Hi Temp Switch (W.O. 24004778). Install a new DT-1217 for C-28 (W.O. 24002390).
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: MI-2 ReactoF Protective Trip Units M0-38 Auxiliary Feedwater System Q0-21 Auxiliary Feedwater System Valve, Inservice Test Procedure M0-2A-1 Emergency Diesel Generator Q0-15 Inservice Test of Component Cooling Pumps DW0-1 Daily Control Room Surveillanc SH0-1 Operators Shift Surveillanc RI-81-A Containment Hydrogen Monitoring System Test RI-17 Main Steam Isolation Valve Circuits Test and Valve Closure Timing.
The inspector.reviewed the master copy of RI-17 (Revision 10 dated January 31, 1989) and the test performed on November 8, 198 The test accomplished the stated purpose by demonstrating that Main Steam Isolation check valves will close in five second However, the test also verified that feedwater bypass and regulating valves close from steam generator low pressure. This was a modification added in 1980 to minimize peak containment pressure effect from a main steam line break with continuous feed to a faulted steam generato Neither the purpose section, the acceptance criteria or basis document addressed this functio Feedwater bypass valve CV-0735 failed to close during the test performed on November 8, 1988, when a steam generator low pressure signal was applie Work Order 24806583 resolved the proble The M&TE non-conformance check sheet, attached to the test and the work order, concluded that there was no consequence on the plant from the failure and was marked no in the blocks for 11Technical Specification other violations 11 and 11 safety function".
The safety function is discussed above and the feedwater isolation logic is documented in Standing Order 54, 11Supplemental Technical Specifications." A yes would appear to be the proper indication for both blocks and would require that a higher tier corrective action document-be writte The inspector has discussed the safety significance of the byp_ass valve failure to close with members of the plant staff and concluded that the safety significance is minor because of the line siz The inspector suggested a possible procedure enhancement of including the safety significance of the feedwater regulating and bypass valves in the procedure purpose and the basis documen No violations, deviations, unresolved, or open items were identifie.
f1re 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 combustibles and on maintaining continuous ready access to fire fighting equipment and materials, was included in the items evaluate On July 25 the inspector observed an after-hours fire drill with response from the Covert and South Haven fire departmen The drill seemed well coordinated and was completed without difficult On August 13 a fire occurred in the 118 11 evaporator area. Apparently a heat trace circuit overheated causing the heat trace material to ignite. The plant fire brigade was able to extinguish the fire in less then 10 minutes and did not require offsite assistance. It appears that a recent repair activity may have placed the controlling
...
thermocouple in such a manner that it couldn't detect the heat trace it was controlling. This permitted continuous operation of the heat trace and the fir Licensee reviews are continuing and will be documented on D-PAL-90-19 This is an open item pending review of the licensee evaluation by the resident inspecto (Open Item 255/90018-03(DRP))
One open item and no violations, deviations or unresolved items were identifie.
~ecurit.l_lZlZ07)
Routine facility security measures, including control of access for
.
vehicles, packages and personnel, were observe Performance of dedicated physical security equipment was verified during inspections in various plant area The activities of the professional security force in maintaining facility security protection were occasionally examined or reviewed, and interviews were occasionally conducted with security force member During a tour of the protected area, the inspector found an unattended vehicle with the keys in the ignition. This was identified to a security officer who removed the keys and initiated an internal corrective action documen During the following weeks, the inspector examined approximately 60 unattended vehicles and verified that the keys were remove In addition, the inspector verified that the internal corrective action document was initiated and, by discussion with the property protection manager, that a check of the internal corrective system did not identify a generic proble Based on the above, the inspector has no additional question No violations, deviations, unresolved or open items were identifie.
Reportable Events (92700, 92720)
The inspector reviewed the following Licensee Event Reports (LERs) by means of direct observation, discussions with licensee personnel, and review of record The review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Closed) LER 255/88013 Revision 2 and 3:
Inoperable C6ntrol Room Ventilation Syste Revision 1 was closed in special Inspection Report No. 50-255/89002 when enforcement action was take Revision 2 was issued to update the LER by providing results of an analysis to show compliance with General Design Criterion 1 This revision was reviewed by a Region III Control Room HVAC specialist; no additional questions were identified.
- Revision 3 was issued to update the LER by providing final information regarding control room HVAC modifications. This revision discussed two modification The first modification pertained to the installation of vestibule The inspector has observed the installation of these vestibule The second modification pertains to the automatic switch to the emergency mode upon detection of airborne activit No additional violations, deviations, unresolved or open items were identifie On August 17, the inspector received a telephone call from a concerned citizen with an allegation that a construction worker had smoked marijuana and passed the licensee fitness-for-duty progra This information was discussed with Region III. The name of the construction worker was provided to the licensee during a conference call later that da The licensee determined that three constructibn worker~ had a name similar to the one provided by the calle Two of the construction workers had passed fitness-for-duty testing but were not working at Palisades (they were laid off when their work assignment was completed).
The other individual had not and was not required to complete the fitness-for-duty testing because his work assignment did not require protected area acces The NRC attempted to contact the concerned citizen and confirm the spelling of the.construction worker 1 s name and, if possible, the name of the company that employed the worke Attempts to contact the concerned citizen failed because the telephone number provided was false. This information was provided to the licensee on August 2 Any additional information pertaining to this subject will be discussed by separate correspondenc No violations, deviations, unresolved or open items were identifie.
Design Changes Facility Change 906 11Modify Main Feedwater Regulating Valve (CV-0701 and CV-0703) and Main Feedwater Bypass Valves (CV-0734 and CV-0735) control circuit to close on Containment High Pressure Signal
(1) The licensee safety evaluation of Facility Change 906 determined that the modification did not require a Technical Specification change request. This was justified by stating that the Technical Specification sections reviewed were not affected by the modification. The safety review form (Attachment 1 to Procedure 3.07, 11Safety Evaluation
) in Paragraph 4 asked the question, 11Does this item require a change to the Technical Specification?
A yes to this question required (per Paragraph 5.2.d of Procedure 3.07) that a Technical Specification Change Request be initiated *
Reviews by the resident inspector determined that Technical Specification Table 3.16.1 (Item 1) lists four actuations initiated by containment high pressure (CHP).
Facility Change 906 modified the CHP logic to perform a fifth function; isolation of feedwate In addition, Table 4.1.2 (Item 4.b)
lists surveillance requirements for the CHP channels and states that a simulation of CHP 2/4 logic trip verifies actuation logic for SIS, containment isolation and containment spray. It appears that the surveillance should be revised to include feedwater isolatio As described in the Notice of Violation, failure to comply with Administrative Procedure 3.07 by not initiating a Technical Specification Change Request is a violation of 10 CFR 50, Appendix B, Criterion (Violation 255/90018-04(DRP)).
During discussions with the NRR Project Manager and a Region III Section Chief, the inspector was informed that the need for a Technical Specification change request was discussed on three separate occasions with the license (2)
This modification used the left channel CHP circuit to isolate feedwater to the 11A 11 steam generator and the right channe.l CHP circuit to isolate feedwater to the 118 11 steam generato With this logic, the faulted steam generator coincident with a failure of the associated CHP logic, would still result in continuous feed until low steam generator pressure isolated feedwate The inspector asked why the modification did not implement similar logic used for closure of the Main Steam Isolation valves; activation of either CHP circuits would isolate the main*Steam Isolation valve The licensee responded by reference to a February 28, 1986, Safety Evaluation by the office of Nuclear Reactor Regulation on Main Steam Line-Break-Single Failures. The safety evaluation concluded that the incremental increase in safety obtained by the proposed modifications which would be major in nature was not cost-beneficial. The inspector agrees with the licensee that Facility Change 906 implements the single failure logic approved by the safety evaluation but questions if it is appropriate to apply the safety evaluation to this modification since the modification consisted of connecting lines between two panels within the control room and did not appear to be a major financial projec The inspector questioned the licensee with regard to the appropriateness of applying single failure aspects of the SER without addressing the cost of the modification. This is an open item pendin~ the licensee evaluation (Open Item 255/90018-5a(DRP)).
The inspector also questioned the need to report to the NRC instances involving SERs used to justify a modification not specifically addressed by the SER (Open Item 255/90018-5b(DRP)).
' Facility Change 466 11Closure of Feedwater Control Valves On Low_
Steam Generator Pressure.
The modification (implemented in 1980)
mitigated the consequences of a main steam line break inside the containment with continuous feed by closing the feedwater valves on steam generator low pressur The licensee safety evaluation determined that a Technical Specification Change Request was not required. Technical Specification Table 3.16.1 (Item 4) lists the Low Steam Generator Pressure signal and states that it isolates the Main Steam Isolation valve As the result of Facility Change 466, low pressure also activates feedwater isolatio The surveillance requirements of Table 4.1.2 requires testing of the Main Steam Isolation valve circuits per Item 16, which implies that a similar surveillance requirement should be stated for feed isolation circuit This item normally would be considered a second example of the violation discussed above, however, the date of the modification precedes the current revision of Administrative Procedure 3.0 The inspector cautioned the licensee to consider this example when formulating corrective action for the violatio For the two modifications discussed above the licensee modified the feedwater valves to close in response to Containment High Pressure or Steam Generator Low Pressure to automatically mitigate the consequences of a main steam line break with continuous feed from the condensate pump Prior to these modifications, the feedwater valves were not used to automatically mitigate the accident and were not addressed in the Technical Specificatio The 10 CFR 50.59 evaluation addressed all of the required attributes necessary to perform an adequate safety revie However, a Technical Specification change was not pursued because the utility did not recognize the need to revise Technical Specifications after implementation of 11 conservative 11 modification The utility will review this apparent hole in its program for corrective actio The licensee discussed the results of the engineering design self assessment with the inspecto The results have not been implemented, however, it is apparent the licensee has determined the need to perform a critical self review to improve performanc This is the fourth assessment performe One violation, two open items, and no deviations or unresolved items were identifie.
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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.c, 3.e, and 6.b, 10.a(2) and 10. *
1 Management Meeting (73702)
On July 18, 1990, a management meeting was held in the NRC Region III offic The licensee discussed the following:
steam generator replacement project radiation protection program; corrective actions/lessons learned from previous outages; health physics self-assessment recommendation; radioactive waste issues associated with the State of Michigan and their potential impact on Palisades Nuclear Station; improvements in the corporate ALARA program and management support; and, other issues identified during the recent ALARA team inspectio.
Exit Interview (30703)
The inspector met with licensee representatives (denoted in Paragraph 1)
on August 29, 1990 to discuss the scope and findings of the inspection as discussed belo 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 Topic highlights of the ~xit intervi~w were: The strengths discussed were:
(1)
Improvements in plant cleanliness (Paragraph 3.b.(2)).
(2)
The willingness to discuss potential Technical Specification problems prior to implementation (Paragraph 3.d).
(3)
An item added to the report and not discussed at the exit was the Engineering Design Self Assessment (Paragraph 10.d). This is the fourth Self Assessment performed indicating that the licensee recognized a need to perform critical self evaluations to improve performanc One potential weakness pertains to storage of defective electronic dosimeters (Paragraph 3.b(l)) resulting in the potential for negative training as people become accustomed to the alar The violation (Failure to submit a Technical Specification Change Request (Paragraph 10) was discusse Initially this was considered a 10 CFR 50.59 violation for not submitting a Technical Specification Change Reques Subsequent reviews after the exit, however, determined that the problem exists with the execution of the plant procedure that implements the 10 CFR 50.59 review proces The five open items were discussed, with emphasis placed on the two (SIT level calibration and use of an SER) that require licensee action. The other three are captured by the corrective action system and appear resolvable when the corrective action document is complet The allegation (Paragraph 9) was discussed, with the conclusion that any additional questions will be relayed by separate correspondenc Vehicle key control (Paragraph 7) was discussed, with the conclusion that the problem was minor, not generic and did not require additional actio