IR 05000255/1990024
| ML18057A546 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/25/1990 |
| From: | Nejfelt G, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A545 | List: |
| References | |
| 50-255-90-24, NUDOCS 9011010318 | |
| Download: ML18057A546 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION.I I I Report No. 50-255/90025(DRS)
Docket N License N DPR-20 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisad~~ Site, Covert, MI * 49043 Inspection Conducted:
October 1 ~ October 5~ 1990 RII I Inspector: ;/J_rfau.ut ~.
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G. M. Nejfelt, RIII Approved By:
~-Lk-.
M; P. Phlllips, Chief Opetational Programs Section Inspection Summar I ti /_xjf b.
Dater
irispection on October 1 - 5, 1990 (Report No. -50-255/90024(DRS))
Areas Inspected:
Routine, announced inspection to follow-up findings from the emergency operating procedure*s (EOPs) team inspection Report No. 50-255/89019(DRS)
for the (1) tmplementation of vendor generic technical.guidelines (GTG)~
(2) overall technical adequacy of EOPs, (3) validation and verification (V&V)
program, (4) EOP training effectiveness, and (5) ongbing evaluation of EOP *Results: All concerns identified by the EDP Team Inspection are closed with the exception of violation 50-255/8g019-05, QA Audits for the EDP Devel6pment Progra The additional information that is needed to closed the QA concern is addressed in Paragraph 2.e. Outstanding EOP comment dates in the licensee's tracking system are noted in Paragraph No new open items, violations, or deviations were identified *
9o11010319 901025
~DR ADOCK 05000255 PNU
U.S. NUCLEAR REGULATORY COMMISSION REGION I II Report No. 50-255/90024(-0RS) *
Docket N License N DPR-20 Licensee:
- co~sumers Powe~ Company 1945 West Parnall Road Jackson, MI 4920 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palis~des Site, Covert, MI 49043 Inspection Conducted:
October 1 - October 5, 1990 RII I Inspector:
Approved By:
G~ M. Nejfelt, RIII M. P. Phillips, Chief Ope~ational ~rog~ams Section Inspection Summary Da-te Date Inspection on October ! - 5, 1990 (Reeort No:
-50-255/90024(DR~)).
Areas Inspected:
Routine, announced inspection to follow-up findings from the emergency operating procedures (EOPs) team inspection Report No. 50-255/89019(DRS)
for the (1) implementation of vendor generic technical ~uidelines (GTG),.
(2) overall technical adequacy of EOPs, (3) validation *and verification (V&V)
program; (4) EOP training effectiveness, and (5) dngoing evaluation of EOP Results:
All concerns identified by the EOP Team Inspection are closed with the exception of violation 50-255/89019-05, QA Audits for the EOP Development Progra The additional information that is needed to closed the QA concern is addressed. in Paragraph 2.e *. Outstanding_ EOP co1TU11ent dates in the licensee 1 s tracking system are noted in Paragraph No new open items, violations, or deviations were identified.
- REPORT DETAILS Persohs Contacted
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Consumers. Power Company ( CPCo). Personne 1
- Dusterhoft, B.M., Operations Support Cooidinator
- Frigo, R.J., Operations Staff-Support Supervisor
- Hanson, J.L., Operations Superintendent
- Mccaleb, R., Palisades QA Director
- Rice, R.M~, Plant Operations Manager
.*Roberts, W.L., Senior Lic.ensing Engineer
- Schepers, J~, QA Supervi~or
'*Yeisley, G.Y., Senior QA Engineer Nuclear Regulatory Commission (NRC)
Heller, J.. K. Senior Resident Inspector
- Denotes those present at Exit Interview on October 5, 1990 *. Other members of the Plant Staff (E.g., training, licensing, etc.) were also contacted during the inspection perio.
EOP Team Follow-up Items (92702) * (CLOSED) Unr.esolved Item (255i89019-01 (DRS):
The ma in feedwater system automatic runback feature that would be actuated by either a reactor or a turbine was found to br installed as described in the Final Safety Analysis Report (FSAR) *
No unreviewed safety question existe The licensee's response of November 17~ 1989, for this item was correct (i.e., main feedwater pump runback rate is independent
of the decay heat removal rate).
Also rev~ewed were:
the main feedwater pump runback surveillahc~
and basis for this runback in EOP.l.OY3 The surveillance protedur~
tested the main feedwater pump turbine ramp down of 1.58% per second to a speed corresponding to 5% of full :1oad feedwater flo The EDP 1.0 Basis stated that the steam generators would be overfilled and primary coolant system (PCS) would be excessively -cooled down and de-pressurized without manual intervention~ Therefore manually tripping one main feed pump (e.g., greater than 50% reactor power)
was imperative; and the second main feedwa.ter pump would.be tripped
- as T approached 525° *
ave.
(CLOSED) O&en lte~ 255/89019-02(DRS}: * The associated corrective actions ta en by the licensee to resolve the EDP technical deficiencies were sampled (e.g., 30 of 130 :individual items identified in the EOP Team Inspection Report'and its Attachment II).
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Examples of *individ~al items v~rified were:
references used in EOP addi~ion.of special requir~ments to perform.EOPs, su§h as, racking in breaker, unlocking a key lock switch, etc *
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identification of piping, cables, and procedures used in EOPs *
identification of instrumentation for parameter monitoring7*
conside~ation o~ degraded containment effects for EOP
- instrum~ntation.
esta~lishment 9f special valve lirieup procedures to implement EOPs *
oper,5or failure to locate attachments for EOPs in the control room
- (CLOSED) Violation 255/89019-03(DRS):
Corrective actions taken for the violftion concerning auxiliary operator (AO) EDP training were reviewed
. Specific items verified are:
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AO EDP tasks were identified in "CONSENSUS MEETI-NG REPORT (MI~UTES) OF 4/25/90~
11 Documerit1 ~o. DAP*90*070 (e.g., opening CRD clutch ~~wer feeder breaker
, lining-upi4-90 for gravity feed to T-2
, operating hydrogen recombf§er -, and *alternate methods of supplying auxiliary feedwater ).
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The "Plant Specific Task List 11 with a run-date of 10/04/~0 _
included newly identified AO EOP tasks (E.g., AO training for*
EOP 5.0).
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On-the-j~~ training (OJT} program for AOs has been identified for EOPs
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All AOs have completed the 37 OJT_th~~ wer,e identiff7d as the most important and infrequently performed EOP tasks.
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All AOs have attended classroom training with -licensiH operators for EOP 5.0, STEAM GENERATOR TUBE~RUPTURE".
All AOs attended classroom traini~g for EOPs 1.0 through 9.0 to provide the AOs with additional insight -into accident mitigation eff~9ts and with perspective relative to their assigned tasks.
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EOP training requirements for EOPs were formally established20. (CLOSED) Open Item 255/89019-04(DRS):
Corrective actions taken for EDP training re1ated issues were reviewe Feedback to operators for their suggestions to improve EOPs ~f principally accomplished with Consumers Power Company, FORM 4 ~nother EOP suggestion feedback mechanism was a plant memorandum
. Also RO EOP Basis Training is actively being conducted (E.G.,
. Training Cycles 90-04 and 90-05. have respectively completed EOP Basis Training for EOPs 6.0 and 7.0). (CLOSED) Open Item 255/89019-06 (DRS):
The associated corrective actions taken by the licensee to resolve the EOP Human Factor Deficiencies (50-255/89019-06) were sampled (e.g., 20 of 83 individuals items identified in EDP Team Inspection Report and its Attachment III).
Examples of individual items verified are:
Addition of specific guidance in the EOP Writer's Guide24 EOP validation methodology25 I
Usage control of capitalization and underlining for E026logic statements (e.g., AND, OR,.!£., IF NOT, WHEN, and THEN)
EDP list ~9rmats included unnecessary 11 AND 11 between each condition
inconsistencies between format of component labels used in plant8and the referenced component identification numbers in E0Ps2
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. t EOP b inappropr1a e ranc ing correction of minor technical errors identified in EOPs30 (CLOSED) Open Item 255/89019-07(DRS):
The associated corrective action taken by the licensee to resolve the concerns of the Open Item for Verification and Validation (V&V) Program EOP Development (50-255/89019-07) was sampled (e.g., 12 of 31 individual items identified in EOP Team Inspection Report and its Attachment IV).
Examples of individual items verified were:
Palisades Plant Specific Te§~nical Guidelines (PSTG) usage for verification or validation
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consistency of refer~nce identifications in E0Ps32 *
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independent V&V EDP reviewer33.
V&V coordination between Operations and Training34*
remova 1 of inappropriate reference in V&V procedur_e35
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application of V&V requirement outside the control room accessib.ility of equipment37 No violations, deviations, or unresolved items were identifie.
EOP Commitments The outstanding EOP comments are provided in the licensee's letter of September 17~ 1989, and its supplemental letter of September 28, 199.
Management Interview {30703)
The Inspector met with licensee representatives (denoted in Paragraph 1)
on October 5, 1990; to disc~ss the scope and findings of the. inspectio The licensee did not identify any documents or processes for this report as proprietary.
ENDNOTES USED FOR PALISADES EOP FOLLOW-UP REPORT, 50/255/90024(DRS)
L FSAR Update, Rev. 10, Sec. 7.5.1.3 and 10..
FWS-029, "FEEDWATER REG FEEDPUMP SPEED CONTROL, 11 with approva 1 date of 07/19/9 The frequency is once per refueling cycle; and was last successfully p~~formed on 10/21/8.
EOP 1.0 Basis, Rev. 2, Sec. 3..
Guidance for EOP details was tncorporated into AP 4.06, Rev. 2, wit MRN A-90-04.
Examples of special requirements added ~~re: in EOP 3.0, Re ~
Step 57, added "racking out breaker" and location information for valves and breakers; and in EOP 5.0, Attachment 2, Rev. 2, use of a prob.
Licensee committed to incorporate method of supplying portable emergency air or nitrogen to operate.steam generator atmospheric steam dump in their tracking sy~tem for the EOP Team Inspection as Item Nos. 23, 30, and 3 * *Average CET (Core Ex.it Thermocouple) value" is used in EOP 3.0, Rev. 1, Sec. 4.0. On 10/03/90, the inspector noted that the ruler used to measur~ recorder ~hould b~ a controlled operator aid (QA) per AP 4.09, Rev. This iuler was classified as QA-112 on 10/04/90~ Licensee committed to perform an engineering analysis (EA) by 10/31/90 with incorporation into EOPs by 02/28/91. -
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SOP 17B, Attachment 1, Rev. 14,.was added to ~rovide valve lineup to
- iransfer waste holdup tank fluid to a filter waste monitor tank or to a clean waste receiving tan Al~o, a section was established in SOP 12, Sec. 7. 5, Rev. 14 to gravity feed condensate water from the primary system to conden.sate storage tan *
1 The isolated case noted in the EOP Team Inspection Report was *caused by the failure to document in the "Daily Orders" that the EOP attachments were moved into the control room proper. Correct application of AP 4.00, Rev. 8, would prec~ude recurrenc *
1 Licensee responded to the "Notice of Violations"-in their letter of September 17, 198.
EOP 1.0, "STANDARD POST TRIP ACTIONS," Re ~ Contingency 4..
. 13 EOP 2.0, 11 AREACTOR TRIP RECOVERY,
Rev~ 2, Attachment 3..
EOP 4.0, 11 LOSS OF COOLANT ACCIDENT RECOVERY, 11 Steps 4.14.d and 4.5.
EOP r~ 0' II LOSS OF ALL FEEDWATER (LOF)., II Rev. 2' Attachment..
See Palisades Nuclear Plant, Part II, ON-THE-JOB.TRAINING MANUAL FOR*
AUXILIARY OPERATORS, Rev. 4, Attachment 9 (E.G., AO operation of the hydrogen recombiners is identified in Item No. 35).
1 AO OJT Requalification Training between 09/89 and 03/90 was reviewed for each crew and was found to be satisfactory. The 17 OJTs committed to be done by 03/01/90 for this vio*lation was included in this AO trainin.
11 Palisades Licensed Operator & Auxiliary Operator Requa~ification Schedule, 11 Rev. 1, with issue dated of 08/04/89, was checked satisfactorily against the Nuclear Training Department (NTD) Attendance Sheets for Class No. 89-0.
See 11 Correction Action Sheet 11 of 06/25/90, Licensee's Document N E-PAL-89-051.
See AP 4.06, Rev. 2, with MRN !-90-041. *
21.. For an applic-ation of an operator EOP suggestion see, Palisade Memorandum of 01/11/88, Document* No. RJF88*00 NOTE:
The Form 40 uses carbon papers to make two copies from the origina.
Palisades Memorandum of 01/09/87, Document No. RAF87*00.
Question paraphrased licensee's initially response* of 09/17/89, ~ AP 4.06, Rev. 2, with MRN-A-90-041, ~dded detaii for:
(1) component description in Attachment 1; (2) referencing AP 10.51, Rev. 1, to describe type of information that should be included in *caution statements and notes; and (3) compcinent location.*
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2 AP 4.06, Rev. 2, Sec. 6.6, designated the simulator as the primary EOP validation method (e.g., personnel certification).
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2 AP 4.06, Rev. 2, Sec. 6.3.2.e and f, by MRN-A-90-041,-delineated the requirements using underlining and capitalization in EOP.
Extraneous usage of 11ANDs 11 were removed in the EOP revisions of July 1990, Rev. *
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2 The EOP revision in July 1990~ Rev~ 2, changed the~tOP identification numbers to match the in plant labels (e.g.,
11MV779CA 11 was -changed i~ fOPs to 11MV-CA779 11 ).
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2 EOPs revised in July 1990 removed redundant steps (e.g., EOP 3.0, Rev. 0, Steps 77 and 78, were deleted and applicable jnformation was incorporated ih EOP 3.0, Rev. 1, Step 73).
Examples of EOP deficiencies corrected:
(1) removal of blowdown tank vent valve, MV-MW158, from EOP 5.0, Attachment 5, Step*, by
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MRN-0-89-264; (2) removal of instant transfer cutoff (ITC) switch from EOP 3.0, Step 8.b, by MRN-0-89-266; and (3) corr-ection of Technica_l Data*
Book figure reference for EOP 5.0, Rev. 1, Step.
No change to the PSTGs are planned by the facility, because the Palisades
.PSTGs have proven suctessful as current written and no significant programmatic changes are foreseen by plant managemen.
AP 4.06, Rev. 2, Sec. 6.3.3.1, by MRN-A-90~041, provided sufficient details a~d examples to use a reference in the EOP. AP-4.06, Sect. 6.5.2, was revised by MRN A-90-041 to ensure independent EOP review by the technical reviewer and validation tea.
AP 4.05, "Operator Training, 11 Rev. 4, Section 5.6, designates the Curriculum Committee to be the common interface between Operations and Training to determining training content and requalification* frequenc Example cited in the EOP Team. Ins~ection Report of not communicating operational needs to Training Department was considered an isolated
- occurrenc. *Reference to te.chnical notebooks was removed in AP-4.06, Rev. _.
AP-4.06, Rev. 2, Sections 6.6.4.a.2 and 6.6.4.e, by MRN-A-90-041, extend EOP verification requirement into the plan.
Steam trap, ST-8641, was deleted from EOP 5.0, by MRN-0-89-293; and required that an acce~sible ~team trap, ST-8928, be use