IR 05000255/1991002
| ML18057A733 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/31/1991 |
| From: | Gardner R, Westberg R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A732 | List: |
| References | |
| 50-255-91-02, 50-255-91-2, NUDOCS 9102120046 | |
| Download: ML18057A733 (8) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION II I Report Number 50-255/91002(DRS);
Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Palisades Nuclear Generating Plant
. Inspection At: Palisades Site, Cover_t, M_I Inspection Conducted: January 7~11~ 1991
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Inspector:
~
. Rolf A. Westberg
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Approved by: ~~
.
- *..
~Ronald N. Gardner, Chief
t Plant Systems Section Inspection Summary:
License No. DPR-20 d~\\l'tl Date:
Inspection on January 7-11. 1991 (Report No. 255/91002(DRS)).
Areas *Inspected: Special announced inspection relative to licensee action on previously identified inspection findings (92701); generic letter followup (92703); and licensee implementati_on of the ATWS rule,.IO CFR 50.. 62, per Temporary Instruction 2500/20 (25020), (SIMS Number MPA-A-20).
Results: No violations or deviations were identified. TI 2500/20 and Generic Letter 85-06 were close Seve~ previously ideritifi~d _inspection findings were close The inspector noted the following:
The level of Quality Assurance applied to th~ ATWS modifications
~enerally exceeded the guidance given in Generi~ Lett~r 85-06.
9102120046 910131 PDR ADOCK 05000255 G
DETAILS
. Personnel Contacted Consumers Power Company CPCo K. Toner, Projects Superintendent
~. Westerhoff, I&C Engineering M. Wape, ESS EE/I&C Sectfon Head R. Massa, Shift Supervisor G. Groff, Control Operator G. Silcock, Licensed Auxiliary Operator
- D. VandeWallle, Plant Safety/Licensing Director
- M. Farens, Palisades Proj~cts Electrical/I&C
- C. Hillman, Plant Licensing -
- B. Meredith, l&C Engineering
- D. Agnello, ESS EE/I&C Engineering
- J. Kuemin, Licensing Administrator
- J. Petro, Section Head - Quality Engineering Nuclear Regulatory Commission (NRC)
- J. Heller, Senior Resident Inspector
- Denotes personnel who attended the exit interview on January 11, 1991, at the Palisades sit Licensee Action on Previous Inspection Findings (92701) (Closed) Violation (89007-011): Spec Change (SC) No.97-090 changed the service water leak detection setpoint from 75 GPM to 300 G~M without verifying what size of piping break in the containment air coolers would result in* a 300 GPM delta-flow alar The inspector reviewed the licensee's response to this violation and found it acceptable. This violation is considered close (Closed) Violation (89007-0lm): SC No.87-163 added a series voltage regulating zener diode to the feedwater (FW) flow transmitter instrument. loop without specifying the zener design parameter The inspector reviewed the licensee's response to this violation and the documentation supporting closure of licensee eventreport No. E-PAL-89-031A and found them acceptabl This violation is considered close (Closed) Violation (89007-0ln): SC No.88-069 added a series voltage regulating zener diode to the Safety Injection (SIJ tank pressure transmitter instrument loop without specifying the zener design parameter The inspector reviewed the licensee's response to this violation and the documentation supporting closure of licensee event report No. E-PAL-89-031A and found them acceptable.
This violation is considered close **
- *(Closed) Violation (89007-0lo): SC 88-069 did not consider the*
effect of instrument loop loading on the power supply~ The inspector reviewed the licensee's response to this violation and the documentation supporting closure of licensee event report N E-PAL-897031A* and found them acceptable.* This violation is considered close (Closed) Violation (89007-0lp): SC No.88-102 installed a different model containment pressure transmitter th~n the one installed without performing a seismic analysis to determine the acceptability of installing the new* transmitter on the old mountin The inspector reviewed the licensee's response to this violation and the documentation supporting closure of licensee event report N E~PAL-89-0318 and found them acceptable. This violation*is considered close f~
(Closed) Violation (89007-0lr): SC No.87-163 added a series voltage regulating zener diode without specifying measurement of power supply, zener, and transmitter voltage as acceptance
.triteria. Th~ inspector reviewed the licensee's response to this
- violation and the documentatio.n supporting closure of licensee event report N E~PAL-89~031A and fourid them acceptabl Thi~
violation is considered close g. *
(Closed) Violation (89007-0ls): SC No.88-069 added a series voltage regulating zener di.ode witho~t specifying measurement of power supply, zener, and transmitte.r voltage as acceptance criteria.. The inspector reviewed the licensee's response to this violation and the documentation supporting closure of licensee evemt report No. E-PAL-89-031A and found them acceptable. This violation is considere9 closed!
- Generic Letter Follow Up (93703). (Closed) Ge~eric Letter 85-06: "Quality Assurance Guidance for ATWS Equipment That. Is Not Safety-Related"~
The inspector verified that the licensee generally met or e~ceeded the supplemental QA controls 9uidance given in GL 85~06 (See Section 4.of thi~ report~) Gl 85-06 is considered close (Closed) Tem~orary* instruction (TI 2500/20) (SIMS Number MPA-A-20)
10 CFR 50. 62*, "The ATWS Rule", requires that each pressurized water
. reactor have equipment from sensor output to final actuation device, that is diverse from the reactot ttip ~ystem (RPS), to automatically initiate the auxiliary (or emergency) feedwater system and initiate a turbine trip (DTT) under conditions indicative of an ATW This equipment must be designed to perform its function in a reliable manner and be independent (from sensor output to the final actuation device)
.. *
from the existing reactor trip syste In addition, each pressuriied water reactor manufactured by Combustion Engineering or by Babcock and Wilcox must have a diverse scram system (DSS) from the sensor output tci the control rods. This scram system must be designed to perform its function in a reliable manner and be independent from the existing reactor trip system (from sensor to interruptidn of power to the control rods).
- The Palisades plant specific design was approved by the NRC in an SER dated December 5, I98 However, the SER contained three open item The open items pertained to the qualification of the isolation devices
.. between non-Class IE and Class IE systems, completion of a failure modes
- and effeets analysis between the RPS and the auxiliary feedwater actuation system (AFAS), and eviluation of the adequacy nf the shared
- annunciator window for the DS The SER also considered the existing AFAS, a Class IE system, as equivalent to the diverse AFAS required by the ATWS rule. Therefore, the plant was only required to install the DSS and the DTT and assure that there was diversity between the RPS and the AFAS circuits. The modifications were installed during the I990 steam generator replacement outage and testing was in process during this implementation inspectio *
The objective of this inspection was to determine whether the DSS and the AFAS complied with the IO CFR 50.62 rule requirements and whether the QA controls applied to the major activities (design, procurement, installation, and testing) for DSS equipment complied with Generic Letter 85-06, "QA Guidance for ATWS Equipment That Is Not Safety-Rel ated," or with IO CFR 50, Appendix B.. The inspection.did n6t assess the operational adequacy and reliability of the installed equipment
because the systems were not yet fully tested or declared operationa The inspector verified the f~llowing aspects of the Palisades ATWS mitigating system Design Engineering Review of the schematics, elementary diagrams, site specific design submittal s, and the ATWS Facility Change confirmed that the Palisades design and.its implementation did not compromise the safety features of the existing safety-related reactor prQtection system Walkdown*of selected portions of the ATWS systems also supported this conclusio *
Review of the ATWS modification package and walkdown of the systems indicated that the design endorsed by the NRR SER was properly implemente The SER delineated three items that required resoluti~n by*the audit process during this implementation inspectio The inspector's conclusions follow:
(1)
Qualification of Isolation Devices The inspector reviewed the documentation supporting the *
qualification of the Rochester dual input voltage alarms*
used as isolators between the pressurizer Class lE instrument loop and thenon-lE logi"c matrix relays alld the dbcumentation supporting the qualification of the Telemechanique type JlO 120 Vac and type Jl3 125 Vdc relays used as logic matrix relays and.the loss of DC alarm relay which starts the steam driven auxiliary feed pum These documents adequately established the qualification of these device *
(2)
Failure Modes and Effect-Analysis*
The-inspector reviewed the project failure mode and effects analysis and* determined that the analyses supported the following conclusions:
(a)
.No single power source failure would disable both the RPS and the ATWS trip functio {b)
No single power source failure would fail the RPS trip function in the unsafe directio (3)
Shared ATWS Annunciator Window The st~ff was concerned that both the ATWS
~Trip" and
"Bypass" conditions were annunciated on a common window since the illumination of the window could represen opposite condition The inspector observed the ATWS annunciator plac~ment in the control room and interviewed several licensed control. room operators and supervisors relative-to the shared.annunciator concer The. inspector concluded that the annunciator was acceptable as designed for the following reasons:
{a)
{b).
The DSS maintenance/testing bypass with the subsequent indication of bypass {annunciator illuminated) can only be actuated by a key operated switch on the control pane *
Entering the bypass condition is procedurally controlled which ensures that the operators are aware of this conditio Procurement and Installation of ATWS Mitigating Equipment The inspector verified the following aspects of the ATWS installation:
(1)
The inspector selected three of the procurement packages at random and verified that the.technical requirements of the Palisades site specific design were in compliance with the SER and the ATWS rul (2)
(3)
(4)
Through review of the selected procurement packages, the
. inspector determined that receipt inspection, identification, and storage controls were employed for the ATWS facility change. A tour of the warehouse indicated that these controls were still in place for the spare parts purchased for the ATWS projec *
The irispector verified traceability of the DSS equipment identifjcation designations and the quality documentation duririg the tour of the warehouse and the system walkdow During the walkdown the inspector also observed permanent nameplates for the installed equipment and the temporary ID numbers used for constructio Through review of the modification package, the inspector verified that the latest specifications, drawings, and procedures were employed for the ATWS facility chang (5)
Walkdown of the installed ATWS systems verified that the equipment installed.met the design requirements for physical, dimensional, and operatiorial characteristics.
- (6)
The ATWS modification was fully installed at the time of this inspection. During the walkdown of the systems, the inspector ~erified that the equipment was installed in the proper location and that it was oriented and supported as specified iri th~ facility chang The inspector ~lso.
reviewed all the design changes that were ~enerated duririg the installation of the equipment with acceptable result. (7)
(8)
Review of the modification installation procedure verified that the equipment was installed using suitable equipment in accordance with established procedures and that proper housekeeping, radiological, and fire protection *controls were employe During the walkdown, the inspe2tor ve~ified that the plint's physical separation criteria for maintaining electrical independence between redundant safety-related circuits and between safety and non safety-related circuits were satisfied. The inspector also verified that qualified isolation devices were u~ed to interface between the non safety related-portions of the ATWS systems. and existing safety-related protection systems, as required by the ATWS rul. *
(9)
Review of the installation proc~dure confirmed that quality*
control inspections were performed using inspection plans developed by quality assurance personne (10) *Review of the deviation reports and nonconforrilance reports generated during the ATWS facility-change verified that they were corrected in a timely manne Confirmation of Completed Work At the time of this inspection, the ATWS systems required by the ATWS rule were fully installed but had not been fully tested or declared operational. Therefore, the inspector was not able to assess the testing of the systems or their operational adequacy and reliability. The inspector observed the following:
(1)
(2)
Control room personnel had been trained on the ATWS facility change and operation of the ATWS system The operating procedures that will reference ATWS systems had not yet been revise The inspector reviewed the
.
proposed changes to the operating procedure The changes were acceptabl (3)
Surveillance or maintenance procedures were not yet implemented for the ATWS systems at the tjme of the inspection. This was due in part because the systems were not safety grade and the fact that the NRC ~as still evaluating the need for Technical S~ecifications for the ATWS system The inspector discussed with licensee personnel the ATWS Rule's requirements that the system
"perform its function in a reliable manner" and be testable at powe The irispector's position was that while the Industry and NRC were continuing discussions relative to TS requirements for the ATWS systems, soine sort of periodic surveillance of the systems should be accomplished at power and that the $ystem logic and actuation devices should be tested end to end during subsequent refueling outage At the exit meeting conducted on ~ite on January ll, 1990, the licensee agreed with the inspector's position and committed to implement periodic surveillance/maintenance testing of *
the systems and to implement end to end testing of the systems during refueling outages. *Pending NRC review of the licensee's proposed ATWS system testing, this item is considered unresolved (255/91002-0l(DRS)).
(4)
The inspector verified that the ATWS systems were being routinely pre-operationally t~sted following the installation of the modifications; however, at the time of this inspection testing had not yet been complete The inspector reviewed the test procedure with acceptable result !
- *
(5)
During a tour of the control room the inspector verified that there was a permanently i nsta 11 ed. key switch to bypass the system for maintenance and testing. The inspector also verified that there was an anriunciator window that gave a continuous indication of the bypas~ status in the control roo * (6)
Through a review of the logic diagrams, the inspector verified that once the mitigative action was initiated, the
- action seals in and the action goes to completio The inspector also verified that subsequent return to normal.
operation could be accomplished by deli berate.actions of the operators utilizing reset switche Quality As~urance And Qualifications (1)
The inspector reviewed the documented ATWS QA program plans and completed QC inspection report The quality assurance applied to the ATWS modification generally exceeded the guidance given *;n Generic Letter 85-0 (2)
Through direct observation and interviews with key lic~nsee engineering and operations personnel, the inspector verified that the personnel responsible for supervising and implementing the ATWS systems were knowledgeable and capable.
Exit Interview
- The inspect6r met with the licensee's representatives (denoted in Paragraph 1) during and at the* conclusion of the inspection on January 11, 199 The inspector sum.marized the scope and results of the inspection ~rid discussed the likely content of the inspection repo~t with regard to documents or processes reviewed by the inspectors. The licensee did not identify any such documents or processes as proprietary.
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