IR 05000255/1990031
| ML18057A669 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/14/1990 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A667 | List: |
| References | |
| TASK-1.C.1, TASK-2.E.4.1, TASK-2.K.3.05, TASK-TM 50-255-90-31, NUDOCS 9012270155 | |
| Download: ML18057A669 (15) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report N ~55/9003l(DRP)
Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Inspect.ion.A.t:
Palisades Nuclear Generating Plant
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Palisad~s Site, Covert, Michigan Inspection Conducted:
October 11 through November 27, 1999 Inspectors:
J. K. Heller J. A. Hopkins T. J. Kobetz B. E. Holian
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.... ~. *<:. J-Jv..-'v~"-<..A-~J Approved By:~~B. L. Jorgensen, Chief -
Reactor Projects Section 2A Inspection Summary I ~- - I u *- cy.,
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Date Ins~ection on October 11 through Novembe~ 27, 1990 {Report N /9oo31(DRP)).
Areas Inspected:
Routine unannounced inspection by the resident inspectors of
.actions on previoosly identified items, plant operations, maintenance, surveillance, steam generator replacement activities, and NRC Region III request The following Safety Issues Management System {SIMS) TMI Action Items were reviewed and closed TMI Action Items II.K.3.5.B "Automatic Trip of Reactor Coolant Pumps 11 II.E.4.1.2 "Hydrogen Recombiners Procedures,"
I.C.1.2.B "Inadequate Core Cooling" and I.C.1.3.B "Transient and Accident Procedures".
Results: No violations or deviations were identified in the six areas inspecte The strengths, weakne_sses, and open items are *discussed in paragraph 8, "Management Interview".
9012270155*901214 PDR ADOCK 05000255 Q
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- DETAILS Persons Contacted Consumers Power Company
- G. B. Slade, Plant General Manag~r
- 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. E. Mccaleb, Director of site Quality Assurance K. E. Osborne, System Engineering Superintendent M. D. King, System Engineering Section Chief*
L. J. Kenaga, Health Physics Superintendent
- W.. L. Roberts, Senior Licensing Analyst K. A. Toner, Plant Projects Superintendent Nuclear Regulatory Commission (NRC)
J. K. Heller, Senior Reiident Inspector J. A. Hopkins, Resident Inspector
- Denotes some of those present at the resident inspector exit interview on November 3 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 It~ms (92701, 92702) (Closed) Open item 255/8700l(DRS):
NRC Bulletin 87-01, 11Thinning of Pipe Walls in Nuclear Power>P1ants
- The licensee's response to this Bulletin, dated September 10, 1987, was reviewed by NR The review determined that the licensee has no additional actions. This is documented in a letter dated March 8, 1988, from NRR to Consumers Power Compan (Closed) Open Item 255/87027-09(DRS)~ Methods of implementing task qualifications were based on years in service as opposed to training in task. Because this item has little or no safety significance and has been open for a prolonged period of time, this item is being administratively close (Closed) Open Item 255/88017-0l(DRP):
Evaluate the need to perform a gradual 11 loss of instrument air 11 *
The licensee has determined that a test will be performe The evaluation is documented by internal correspondence A-PAL-90-075 and A-PAL-90-127. (Closed) No number assigned:
Paragraph 6 of Inspection Report No. 50-255/89018(DRP) stated that FSAR Table 9-17 (sheets 3 & 4)
was misleadin The table listed ventilation dampers and
- providea their position during various modes of plant operation and after certain actuation signal The individual damper logic prints did not agree with Table 9-1 The licensee evaluation determined that Table 9-17 was incorrect and submitted an FSAR Change Reques (Closed) *No itsm number:
lns~rvice Testing for the Containment Spray Pump Inspection Report No. 50-255/90006(DRP) documented concerns that two te~ts involving the containment spray pumps use different flow paths but have the same acceptance criteri In a memorandum from G. E. Schrader to J. K Heller the licensee stated the acceptance criteria will be revised for the appropriate tes (Closed) Open Item 255/90015-04(DRP):
While reviewing Facility Change 906 Containment High Pressure Trip Activation for Feedwater Valves" the licensee was asked if a Technical Specification change was required. * Violation 50-255/90018-04 was issued to th~ licensee on this issu The licensee response dated October 15, stated that the Technical Specification Change Request will be submitted and revisions to their Administrative Procedures for Technical Specification Changes will be made by December 1, 199 (Closed) Open Item 255/90015-06(DRP):
It was noted during T-FC-906~001, 11Test Containment High Pressure Trip Activation for Feedwater Valves CV-0701, CV-0735, CV-0703, and CV-0734", that the valves were stroked while the plant was in cold shutdown with no load on the syste The inspector asked if stroke timing under these conditions assured the valve would function within the time assumed during an acciden The valve vendor stated in a letter that because of valve design, plant condition should not affect the stroke timin (Open) Open Item 255/90021-0l(DRP):
Safety Injection and Refueling Water Storage (SIRW) Tank Leakag On October 8, a leak of approximately 25 gal/hr from the SIRW tank was identified. Initial investigation determined that there was no external structural problem. The licensee drained and decontaminated the tank to facilitate internal investigation and repai Liquid dye penetrant (PT) tests of the SIRW tank welds, identified indications of defects on the 6 inch spent fuel pool (SFP) supply and recirculation line The supp.ly line had 3 one-inch linea~
defects and the recirculation line had 1 six-inch crack. The floor plate welds and other pipe penetration welds were free of defect The weld metal for the 6-inch lines was removed to the base metal and new weld metal was installe The new welds were PT examined and were found acceptabl While refilling the SIRW tank the licensee observed minor leakage at the base of the tan The leakage apparently was water trappe~ in the sand between the SIRW tank floor plate and
the foundatio The hydraulic force applied to fhe sand while the tank was filled released the wate The leak rate decreased and eventually stoppe The root cause of ihe initial leakage is still under investigation. This item is still considered an Open Ite No violations, deviations, unresolved or open items were identifie.
Operational Safety Verification (71707, 71710, 42700, 93703)
Routine facility operating activities were observed as conducted in the plant and from the main control roo The performance of Reactor Operators, Senior Reactor Operatrirs, Shift Engineers, and Auxiliary Equipment Operators was observed and*
evaluate Included in the review were procedure use and adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie *
Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems and radiation monitoring system Reviews of surveillance, equipment condition, and tagout logs were conducte Proper return to service of selected components was verified. General The plant began this reporting period in a refueling shutdown condition with the vessel defueled and all fuel in the spent fuel poo The inspector verified by observation, discussion with the control room operators and review of checksheets that the spent fuel pool cooling system was operabl Thts included verification that the fuel pool temperature was maintained, spent fuel ventilation was operable during spent fuel pool activities, cooling water was available to the spent fuel pool heat exchangers, and emergency power was availabl Plant Tours During tours of the containment, auxiliary building, turbine building and the spent fuel storage area, the inspector observed the following:
(1)
A craft laborer appeared to be loitering on the 607 entryway to the "8 11 steam generato This was identified to the area RP technician. Subsequently, the inspector was informed that other individuals (Contractor Supervision and Radiation Protection personnel) had noted the same individual in what appeared to be an inattentive state. The individual was dismissed from his duties.
(2)
Pipefitters, welders and firewatches working on the steam pipe we.Id to the 11A 11 steam generator, were on scaffolding that was approved for use with a safety belt. There were a number of belts -in the area; The firewatch* had one around his waist; however, neither end of the safety rope was attached to secured object. This was discussed with the workers who indicated they had chosen not to use them. This was identified-to the safety officer. During subsequent tours the inspector noted that safety belts were in us (3)
The inspector noted that two 3/4-inch stainless ste~l tubes located in the 118 11 safeguards room (above the doorway to the equipment drain pumps for pressure transmitter PT-1008 and valve MV-619 CRW), were free to move and appeared to be missing a number of supports. This was identified to plant project personnel, who stated that the supports were removed by
. Specification Change (SC)89-188 when bigger piping/supports were remove SC 89-188 is still open and will replace the support Completion of the specification change is scheduled for this* outag (4)
The inspector observed that a tool cabinet was stored in the charging pump cubicles in tipping distance to the 118
charging pum The cabinet was not secured to prevent movement or tippin The fnspector had observed this tool
. cabinet, fn this location, during the last operation cycl This was discussed with the Mechanical Maintenance Superintendent, who indicated that plans were being formulated to secure the tool cabine He also stated that the tool cabinet will be removed from the area prior to power operation if it is not secured in plac Fuel Elevator Checklist Checklist CL 28.2, 11Fuel Elevator Checklist 11, Revision 14, certifies the electrical interlocks associated with the spent fuel pool fuel inspection elevato The following questions were asked:
(1)
Step 3.2 removed the mechanical stop block but did not verify that the mechanical stop will stop the elevato It does not appear that this function is checked in any other checklist. Paragraph 9. 11.3.5 of the FSAR states that mechanical stops are provided on all handling equipment which limit the height of withdrawal of the irradiated fue The inspector asked if the inspection elevator mechanical stop should be tested. This *is an open item pending review by the licensee (Open Item 90031-0l(DRP)).
(2)
Steps 3.3 to 3.5 raise the elevator until it is stopped by the upper electrical inspection limi Then a measurement.
is made from the 649 floor level down to the top of the elevato If this distance is equal to or greater than 10 feet, then the acceptance criteria is satisfied. Palisades
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Plant Drawing M-6 at Section B-B, indicated that the water level starts one foot below the floor leve Operators indi~ated that the operating band can be reduced an additional foo This means that the 10 foot acceptance criteria may only provide eight feet of water shielding if the elevator is at its upper inspection limit and the water level is at its lower operations limi FSAR paragraph 9. 11.3.5. 1, states that adequate shielding for radiation protection of the refueling personnel is provided by the handling of irradiated fuel under 10 feet of wate In addition, paragraph 9. 11.3.5.5 states that because of the submergence of the bundle in 10 feet of water, any released fission products will be diluted and partially retained by the pool wate Thus, the FSAR uses 10 feet of water shielding, *not 10 feet of distance, as the standard for handlingirradiated fue Checklist 28.2 uses 10 feet of distance as the acceptance criteria. The licensee was asked to determine if 10 feet of water shielding was provide This is an open item pending review by the licensee (Open item 255/~0031-02(DRP)).
50.72 Notifications The licensee made the following 50.72 notifications:
(1)
On October 12,* containment Penetration 26 (nitrogen supply)
exceeded its administrative limit by approximately 1100 cc/mi A phone notification was made to NRC per 10 CFR 50.7 On October 29, the corrective action review board (GARB) discussed the reportability aspect and noted that total containment leakage was less than.6 La and that only an administrative limit and not a Technical Specification limit was exceede The GARB determined that reportability instructions to the shift supervisor should be revise On November 7, the licensee retracted this (via the 10 CFR 50.72 telephone network) and twci other 10 CFR 50.72 notifications pertaining to local leakrate testing performed during this outag The inspector had no additional question (2)
On November 10, during post maintenance testing of breaker 106 to the 11C 11 safeguards bus, the fast transfer circuitry was activated causing the bus breaker to open and auto start the dedicated diesel generator. Breaker 106 was in the "Test" position, which should permit testing without affecting the feeder breaker or the fast transfer circuitry. Breaker 106 was subsequently tested in the fully racked in position with satisfactory result The cause of the actuation was the result of operator error and a deficient procedur The procedure cautioned the operator that the actuation may occur; however, the caution was not located at the appropriate step in the procedur The operator was at fault because he had not performed an adequate procedure review prior to us The other systems associated with the fast transfer circuit worked as
designe The 50.72 notification was documented on corrective action document E-PAL-90-045 and will be the subject of a Licensee Event Repor The inspector has no additional questions at this tim (3)
On November 1, configuration control personnel inadvertently shorted power supplies in inverter number Due to plant conditions, this cascaded to a right channel containment isolation and a sump recirculation actuation. For both actuations all systems (except those disabled because of the outage) responded as designe The short was caused when a wooden ruler with a metal strip was inserted in the panel to sepafate wires for wire verificatio This work pr~ctice was one of the subjects addressed by corrective action document E-PAL-90-04 The actuation will be the subject of a Licensee Event Repor The inspector has no additi-0nal questions at this tim (4)
On October 16, the licensee determined that the flow rate, for the hot leg injection flow path, was less than that required by the plant safety analy~is. The test was performed on August 30 and, at that time, the results were below the acceptance
criteria, but sufficient evidence existed to indicate that the reduced flow was acceptabl This event was discussed in
. Licensee Event Report 90018 which was reviewed by an NRC Riil inspection specialist. It will be discussed further in Inspection Report 50-255/90025(DRS).
The membership of the.CARS was reviewed with regard to the above ite On this day an alternate scribe was assigned because the principle scribe was offsite. Reportability requirements are the responsibility of the CARS scrib During discussion with the Director of Safety and Licensing, it was determined that the alternate scribes may not have the same knowledge of reportability requirements as the principle scrib The director stated that training would be provided to alternate scribe No violations, deviations, or ~nresolved items were identifie Two open 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 ensure 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 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: Repair leaking tubes in Spent Fuel Pool Heat Exchangers E-53A & B (Work Orders (WO) 24005883 and 24005855).
Review of the spent fuel pool heat exchanger inspection and repair indicated that the licensee took the proper analytic approac Both heat exchangers were eddy current inspected 100 percent using dual bobbin probes. This probe would indicate wall thinning and patterns of intergranular crackin An 8 X 1
- pancake probe could have been used to determine individual cracks but the iicensee opted not to since all evidence pointed toward tube vibration as the wearing mechanism in lieu of crud buildup or other chemical effect The root cause appears to be wall thinning due to high flow induced vibratio This supported the eddy current data which indicated the tube wear had sharp edges in lieu of rounde Rounded edges would indicate crud buildu Plugging was performed on all tubes with greater than 60 percent walJ thinnin In addition, all ruptured tubes and excessively dented tubes (to the point that prevented inspection) were plugge A followup eddy current inspection is planned in about five years, to determine additional wea Currently, the licensee has no plant-wide heat exchanger test progra Inspections are conducted for the component cooling water (CCW) heat exchanger The feedwater heaters being installed this outage, have had a preinstallation eddy current inspection and will have partial inspections during future outages as time permit The licensee is evaluating the inspection needs for other heat exchanger I-FC-848-NFE-23 11 Fuel Inspection 11 *
The inspector observed disassembly and removal of the fuel bundle upper tie plate per step 5.9. During disassembly, the inspector observed that tools were secured to the side of pool when not in use, were secured to the workman 1s wrist when in use, and were wiped down when removed from the wate In addition, dedicated RP personnel were provided to monitor radiation levels of the work area during vertical movement of the fuel bundl The inspector verified that inspection activities were* secured when the containment construction door was open and that spent fuel pool checklists pertaining to the inspection elevator, water level and ventilation were curren The inspector noted that step 5.9 requires placement of tape on remote handling tools eight feet from the remote en If the tape is used as a safety measure to ensure minimum shielding is available during disassembly, the inspector asked why the FSAR number of 10 feet was not use This was discussed with the 12 *
reactor engineer, who stated that tape was a reminder and that fuel pool shielding was verified by fuel pool checklist The inspector reviewed the applicable checklist (see paragraph for the inspector 1s observations).
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The inspector* also noted that the workman was sitting on the inspection elevator drive mechanism, leaning over 'the side of the pool while using the re~ote handling tool The individual did not use a safety belt. This was discussed with the plant safety officer and the reactor engineer, who felt that the curb of the spent fuel pool and. the arrangement bf the elevator drive mechariism kept the workman 1s center-of-gravitY away from the spent fuel pool and eliminated the need for safety belt Replace hot leg injection check valves ES-3409, 3408 and 3410 per Specification Change (SC)90-023 and WOs 24003222, 24003223 and 2400322 *
The inspector attended the preplanning meeting for the above work*
activities and found that *a project team consisting of approximately 20 team members was in place~ team management/organization/
res pons i bi 1 i ty was documented, and best/wors,t case scenarios were establishe Repair Safety Injection and Refueling Water (SIRW) storage tank per WO 2400593 Install New NI-1/3 Channel in C-06 Panel per Facility Change (FC) 829 and WO 2400344 Install New Turbine Driver per WOs 24801746 and 2400040 Inspect and Repair Main Steam Isolation Valve CV-0510 per WO 2400213 The inspector noted that a copy of the last work order for this component was included in the work order packag The workers indicated that the work order summary had been a good aid in the planning/staging/prejob briefing for this jo No violations, deviations, unresolved or open items were identifie Surveillance (61726, 42700, 60705)
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: Month Calibration of Pressurizer Transmitters and Indicators for Vap6r Phase Temperature and Water Phase Temperature (Work Order (WO) 24005568). RI-95C&D Auxiliary Feedwater Flow FT-0736 Instrument Loop Calibratio Steps 5. 1. l and 5.3. 1 both required an operator signature that the opposite channel was operabl This step was marked N/A which appears appropriate because of plant conditions and words contained in Step The inspector noted that a Signature did not accompany the 11 N/A 11 and the 11 N/A 11 was not justified.. A brief reason by reference to a previous paragraph might make it a more complete, stand alone procedur In addition, the working copy was changed by a hand written (MRN-7-90-161) change request attached to the front of the procedur This change affected Attachments 1 and It was unclear why the change request was not incorporated in the body of the procedur None of the items affected performance; however, these could be areas of improvemen These items were discussed at the exit intervie During the report period, the inspector observed a sample of the new fuel receipt inspection for the 52 new fuel bundles receive The licensee Quality Control Department used Permanent Maintenance*
Procedure (PMP) Number FHS-M-10 11Fuel Receiving Procedure for Advanced Nuclear Fuels (ANF) Fuel
, and Site Inspection Plan/Report (SIP/R) F-OOl(Q)
11 Inspection of ANF Fuel and Reload Components 11, to govern and document the inspectio Two shipping containers (which each hold two fuel bundles) were found with the accelerometers tripped (one internal and the other the left side vertical).
Inspection found no indication of damag All new fuel was stored in the new fuel storage racks and later transferred to the spent fuel poo No violations, deviations, unresolved or open items were identifie.
Steam Generator Replacement Project (37701)
Highlights of the licensee accomplishments during this inspection period are containment concrete cutting and removal, steam generator removal and internment, installation of the new steam generators, installation of the containment liner plate, and the start of *
primary coolant loop weldin The majority of the NRC inspection activities were performed by NRC RIII specialists and documented in Inspection Report No. 255/90025(DRS). The resident inspector observed the following:
(1)
Load test of the containment jib crane per W.P. 5,0 C-007.
(2)
Installation of the containment liner plate per Facility Change (FC) 91 The inspector noted that the hcirizontal and
- vertical stiffeners were not in line with the ones embedded in the concret The vertical stiffeners were uniformly offset by approximately 2 inches. The horizontal stiffeners were offset by 2 to 6' inche This was discussed with Bechtel, Consumers Power Corporation, and the NRR Technical reviewers. *Bechtel stated that the liner was a long lead time procurement item and that assembly of the liner and installation of the stiffeners was done prior to removal of the containment openin The same number of vertical stiffeners, with the same spacing as the original stiffeners, were use The horizontal stiffeners were repositioned to accommodate the weight of the wet concret Consumers Power Company had an analysis showing that positioning of the horizontal stiffeners would provide desired strength during concrete pours. All personnel interviewed agreed that location of the stiffeners should not affect the integrity of the line The inspector did note that the FC did not reflect the change in stiffener location and that the FSAR does describe the purpose and location of the stiffener In addition to the.above, some of the rebar in the lower portion of the op~ning were not reinstalled. Bechtel stated that this rebar was part of the original construction and is _no longer require The two examples addressed above appear to have no safety significance, but are changes to original plant design that were not reflected in the FC packag The inspector asked the licensee if these should be reflected in the FC packag This is an open item pending the licensee review (255/90031-03 (DRP)}.
.
(3)
During a tour of the 11A 11 steam generator work platform on November 27, the inspector observed two flashes coming from one of the cold leg welding heater Th~ first occurred when a person bumped the outer thermal blanket and the second occurred when a person climbed over the cold leg. After the second occurrence a worker indicated that this wis a repeat proble A piece of the outer thermal blanket wis pulled back and the inspector saw evidence that the arcing had occurred a number of time The inspector discussed this with project management, stating that since arcing had occurred a potential personnel safety hazard existed. Further, this could cause localized arc strikes on the cold leg pipin When this was identified at the exit interview, plant personnel indicated this problem had been identified on November 24 during the outage manager's tour and was identified to the Bechtel containment coordinato Based on this information there appeared to be a communication breakdow The licensee was asked to determine if a communication problem did exist. The licensee subsequently determined that the arcing was from two different problems and that each had been resolve (4)
The inspector reviewed Palisades Nuclear Plant Administrative Procedure 9. 03A, 11 Faci 1 ity Change for Steam Generator Rep 1 a cement Projec This procedure was written specifically to define the interface responsibilities between Bechtel and Consumers Power Company for the preparation of facility changes for the replacement projec This permitted Bechtel to perform wgrk in accordance with *
their procedures while.providing necessary inputs, reviews, and
~pprovals by Consu~ers Power Company to ensure design and implementation satisfy licensing commitment (5)
On September 17, a memo was issued from the Vice President of Nuclear Operations to all Nuclear Operations Department and Energy Supply Services employees and contractors. This memo describes the workers' responsibilities pertaining to safety concerns and the path available to identify a concern to managemen In addition, *a copy of the NRC Form 3 was attached to show how concerns are identified to the NR (6)- During tours of the containment, the inspector found that the radiation levels in the hot/cold leg welding area were reduced from approximately 1.5 R/hr to a 20-60 mR/h This appeared to be the result of proper placement of shielding and extensive decontamination work on the exposed ends of the hot/cold legs which permitted piping weld repair and cladding buildup without the use of respirator Discussion with radiation protection personnel indicated that welding did not create any airborne activit (7)
A number of the personnel, performing the loop machining and operating the loop to steam generator weld machines, were foreign nationals who$e native language was Germa To accommodate. this, the radiation "Danger" and "Caution" signs were displayed in both English and Germa NRR inspectors reviewed/observed the following:
(1)
On October 29, the inspector was walking down the initial containment access opening and noticed that one of the concret bore holes, drilled prior to use of the diamond-tipped rope saw, penetrated the sheathing surrounding one of the containment tendon Discussion with contractor personnel working on the containment opening revealed that the tendon sheath and tendon had been damaged during the core bor The tendon and the sheath will be replace The inspector noted Facility Change Package No. 914 "Construction Opening" stated that tendon removal would occur prior to concrete boring which could impact the tendon (2)
A Deviation Report was presented to the CARB on October 30, which detailed a communication breakdown that allowed the Auxiliary Building Containment Access Facility to be used prior to proper approval from the Facility Change Package coordinator (Facility Change Package No. 904 effectively had an administrative hold which should have prevented its implementation).
(3)
On November 9, several representatives from NRR accompanied the Project Manager on a site visit and inspection of 'the ongoing*
Steam Generator Replacement Projec The inspectors inspected the temporary containment access opening, observed removal of the containment rail system.which supported the steam generator removal and observed on-going secondary-side improvements in the turbine buildin In addition, the following facility change packages, specifically comparing the field modifications with the facility change, were reviewed:
FC-904 FC-909 FC-910 FC-914 FC-915 FC-922 FC-923 Auxiliary Building Modification for Containment Access Steam Generator Replacement Primary Coolant System Construction Opening Comp-onent Cooling \\.later Surge Tank Room Modifications Interference Removal and Replacement Feedwater Piping & Narrow Range Instrumentation The facility change package review verified the following:
a)
Actual primary coolant system cladding build-ups met the minimum wall thicknesses specified in the facility change (FC) packag b)
The steam generator tube plugging performed on the new stea~ generators met the guidance in the FC packag Additionally, the appropriate plugs were used (there are currently concerns in the industry over the adequacy of certain plugs).
c)
Revision to FC packages 904 and 915 adequately addressed current plant condition Discussions were held with the licensee concerning concrete crack mapping prior to and during the Structural Integrity Test and the licensee 1s plans for future tendon surveillances since at least one new tendon is planned to be installed. Concrete crack mapping had not started and it was unclear if it was adequately addressed in the FC packag Similarly, a revised tendon surveillance plan had not been incorporated into the FC packag Finally, FC package No. 922 had revisions noted in the margins of the package with no discussion and review of the changes noted on the covershee Licensee resolution of these items wi-11 be reviewed for the Safety Evaluation Report (SER)
and the SER open line item pertaining to the construction opening will be resolved following the structural integrity tes.
NRC Region III Request (TI 2515/065) (Closed) TM! Action Item II.K.3.5.8: Automatic Trip of Reactor Coolant Pump A January 26, 1990, letter from A. W. De Agazio, Sr.,
NRR to file verified that the appropriate trip requirements have been incorporated in EOP No. * (Closed) TMI Action Item II.E.4.l.2:
Hydrogen Recombin~r Procedures Reviewed and U~graded. The electronic hydrogen recombiners are located inside th~ containment and do not require a containment penetratio In addition, the EOP 1s provide instructioni to utilize the hydrogen recombiner~ for combustible gas control during a LOCA, these EOPs were reviewed and the inspector has no further question (Closed) TMI Action Items I.C.1.2.B and I.C.1.3.B: Revise Inadequate Core Cooling Procedures and Transients/Accidents Procedure An Emergency Operating Procedures Team Inspection was performed with the results documented in Inspection Report 50-255/8901 The inspection focused on the EOPs with respect to the licensee 1s EOP upgrade progra The upgrade program was developed utilizing the requirements of Supplement 1 to NUREG-0737 which clarified and developed guidance for the upgrade of EOPs for the industry following the TMI-2 acciden The inspection looked at program deviations from the guidance in the owners group analysis of transients and accidents and specific plant desig The inspection team 1s overall determination was that the licensee 1 s EOPs could be effectively carried out in the plant and could be correctly performed by the licensee. Although a number of human factors concerns were identified, none were determined to pose a significant safety concern. The concerns are being tracked as open items for Inspection Report 50-255/89019(DRS).
No violations, deviations, unresolved or open items were identifie.
Management Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1) on November 30, 1990 to. discuss the scope and findings of the inspectio In addition,J 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 Highlights of the Exit Interview are discussed belo The strengths noted:
( 1 )
( 2")
(3)
(4)
( 5)
The analytic approach used to resolve equipment problems (paragraphs 4.a. and 4.c.)
The use of work order summaries (paragraph 4.g)
Generation of a procedure to allow a contractor to use his procedures while ensuring that plant requirements are implemented (paragraph 6.a(4)).
Publishing instructions pertaining to workers responsibilities (paragraph 6.a(5)).
.
Decontamination efforts and posting of bilingual radiation signs (paragraphs 6.a(6) and(7)).
- The weaknesses noted:
(1) Worker's decision not to follow personnel safety precautions (paragraph 3.b~(2)). -
(2)
Configuration Control Project practices for wire verification (paragraph 3'.d, (3)).
(3)
Permitting a potential personnel and equipment problem to continue without resolution (paragraph 6.a.(3)).
(4)
Implementation of work practices without establishing the prerequisites (paragraph~ 6.b(l) and (2)). The three open items were discussed:
(1)
The first two pertaining to the fuel pool inspection elevator (paragraph 3.c) were discusse The licehsee was asked to assure the the problem with minimum water shielding does not exist with the refueling bridges. * This should be evaluated prior to core reloa (2)
The need to document the difference between the as-found and the as-left condition in the facility change (paragraph 6.a.(2)). The commitment to secure or remove a tool cabinet located adjacent to a pump was restated (paragraph 3.b.(4) The four 10 CFR 50.72 notifications (paragraph 3.d) were discusse At this time, the inspector had no ~dditional question However, additional reviews will be performed when the Licensee Event Reports are issue The inspector confirmed that additional training pertaining to reportability requirements will be provided to CARB alternate scribe members (paragraph 3.d.(4)).