IR 05000255/1991005

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Safety Insp Rept 50-255/91-05 on 910219-0405.No Violations or Deviations Noted.Major Areas Inspected:Actions on Previously Identified Items,Plant Operations,Surveillance, Maint,Design,Changes & Regional Initiatives
ML18057A869
Person / Time
Site: Palisades Entergy icon.png
Issue date: 04/19/1991
From: Jorgensen B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18057A868 List:
References
50-255-91-05, 50-255-91-5, NUDOCS 9104300101
Download: ML18057A869 (25)
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Text

U: S *. NUCLEAR REGULATORY COMM I SS ION REGION II I Report No. 50-255/91005(0-RP)

Docket No. 50-255 Licensee:

Consumers Power Company 212 West Michigan Avenue Jack~on, MI 49201 Facility Name:

Palisades Nuclear Generatfog Plant Irispection At:

Palisades Site, Covert, Michigan Inspection Conducted:

February 19 through April '5, 1991 Inspectors: J. K. Heller, Senior Resident Inspector R._Sch~eibinz, Senior Project Engineer R. L. Bywater, Reactor Engineer G~ Passehl, Resident Inspector D. L. Waters, Consulta~t to NRC Approved By: ~~~~~ief 1-19/91

~~~i~rojects Section 2A Date rn*spection Summary License N DPR~20

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Inspection on February 19 th.rough April 5, 1991 (Report No. 50~255/91005(DRP))

A_reas Inspected:. Routine unannounced inspection by resident and regional inspectors of actions on previously identified items, plant operations, survei.llance, maintenance, design changes, and reg.ional initiative No Safety Issues Management System (SIMS) items were reviewe *

Results:

No violations or deviations were identifie The strengths, weaknesses and Open Items ate detailed irr Paragraph 8,

"Management Intervie *In summary:

Strengths were noted in conservative actions to shut down the unit or limit power level in order to resolve problem Operations management involvement, and department professionalism and ownership of plant evolutions and problem resolution were generally stron Weaknesses were noted in development and implementation of some special test procedures, including integration of these with routine test Examples of these problems caused a grouping of reportable events which were the subject of a licensee~initiated phone conference with NRC Region II PDR ADOCK 05000255 G

. PDR

Minor maintenance planning and work control problems were note Also, modifications were sometimes done using deficient procedures or exhibited inadequate preparations or inattention to detail during development and implementatio **

~--- Pefsons Contacted Consumers Power Company DETAILS.

  • G. B. Slade,* Plant G~neral Manager
  • R. M. Rice, Plant Oper*ations Manager D. J. VandeWalle, Technical Director
  • R. D. Orosz, Engineering and* Maintenance Man.ager
  • J. Hanson~ Ope~attons Superintendent

.- B~ Kasper~ Mechanical Maintenance Superintendent

  • K. E. Osborne, System Engineering Superintendent K. A. Toner, Plant Projects Superintendent
  • T. J. Palmisano, Administrative ~nd Planning Ma~ag~r
  • R. M *. Brzezinski, I&C Superintendent

-

  • R. E. Mccaleb, Quality Assurance Director Nuclear Regulatory Commission (NRC)
  • J~ K. Keller, Senior Resident Inspector
  • E. R. Schweibinz, Senior Project Engineer Parameter In *D. B. Waters, Consultant to NRC
  • Denotes some of those present at the Exit Interviews on March 15, 1991, or April 16, 199 Other members of the plant staff and the Jackson Engineering offices were also contacted during the inspection perio.

Actions on Previously Identified Items {9270i, 92702) (Closed) Open Item 255/90039-02(DRP):

The licensee was asked to determine if the performance characteristics of the new.steam *

generators varied sufficiently from the old ~tea~ generators to warrant natural circulation testing during the restart progra The licensee evaluation (RLB90-014) stated that natur~l circulation was enhanced by the replacement steam generators because system flow resistance (number of plugged tubes) was greatly reduced. Other key factors which influenced natural circulation - such as elevation and temperature differences between the heat source and he.at sinks'

maintenance of subcooled coolant conditions, and absence of non-condensible voids ih the coolant loop - remained essentially unchanged from previous plant operating conditions. The licensee referenced a natural circulation event which occurred on July 14, 1987, as adt;fitional basis for expectations of proper natural circulation performance post-steam generator replacemen The inspector reviewed natural circulation Emergency Operating Procedures, natural ctrculation training conducted on the simulator,

. arid conformity of simulator modeling to the modified steam generator

  • flow and heat transfer characteristics., The inspector concurred with the licensee's justification that additional natural circulation tes.ting was not require *
  • (Closed) Open Item 2S5/90039-03(DRP):, the licensee was asked to evaluate their plans regarding water hammer testing of the main

_feedwatet and/or auxiliary feedwater systems during the steam generator replacement restart progra In response, the licens~e docu~erited a justificatio~ (RLB90-014)

for not performing water hammer testing. This justifiGation was based on.the design characteristics of the replacement steam

generators which reduced the probability of water hammer oc*currence compared to the original steam generators. These characteristits included separate main feedwater and auxiliary feedwater injection points, 11J-tubes 11 on the main feedwater ring to prevent draining *of the ring when flOw is lost, lowering of the auxiliary feedwater nozzle and internal goose neck to below normal water level, welding of.the goose* neck to the auxi 1 iary feedwater piping to minimize draining and steam bubble form~tion, and an admini~trative control program to monitor An/ piping for check valve backleakag Many of these improvements were incorporated prior to the replacement of the steam generators due to water hammer events durin~ the plant's operating histor *

The inspector discussed the response with system engineers and plant operations personnel and observed auxiliary feedwater testing during startup activities at flow rates.~xceeding the normal automatic*

injection rate. The inspector concurred that additional*water ha1TVT1er testing was not war~anted~

  • (Closed) Open Item 255/90039-04(DRP):. The lice~see was asked to determine if thermal expansion ~nd contraction measurements are necessary dur*ing the first cooldown following startup to assess the impact of the replacement projec,t on the primary coolant system and attached pipih In response, the licensee stated that the nuclear steam system supply (NSSS) vendor requirements provided for setting support gaps cold and checking them hot during startup to assure binding of the PCS did not occu The inspector observed the gap measurements and reviewed the results of the measurement The anticipated movement, both in direction and relative amount, of*the steam generators, primary coolant pumps, and r~actor vessel were all within expected range The licensee also perform~d walkdowns of piping and hangers associated with modifications to the blowdown and auxiliary feedwater systems; no significant de~i~iencies were foun * (Clo~ed) Open Item 255/90039-0S(DRP):

During a management meeting on November 28, 1990, the licensee discussed resolution of a leak from the safety injection and refueling water storage tank at the

I

.

.

penetr~t~*Qn to floor plate wel The leakage was the result of floor *.

plate flexing during draining and filling operations associated with refueling outages. Duririg the discuss~on, the licensee was asked.to determine *if the seismic qualification of the tank was affecte he licen~ee ev~luation (RBJ 05~91) concluded that the seismic

  • loadirigs are a small percentage.of the water weigh The tarik and building will tend.to mo~e integrally as a result of the.anchoring mechani~m~. The ev~luation concluded that the seismic qualification was not affecte The evaluation was reviewed by a Region III *

DiviSion of Reactor Safety'-sp*ecialist, who concluded that the overall seismic qual.iftcation did ~ot appear to be affecte. (Closed) Open Item 255/90031~02(DRP): The license~ was asked to *

determine*if 10 feet of water sh~elding was provided while conducting Steps 3.3 to 3.5 of CL 28.2 -Spent Fuel Pool Elevator Inspection".

The licensee.determined that 10 feet of water was maint.ained; however, the..

acceptance criteria of CL 28.2 *as not appropriat CL 28.2 was changed to reflect the correct acceptance criteria. The eval~ation was.documented in Engineering Analysis EA-KFK-90-0 (Closed) Open Item 255/90018-5a(DRP):

Facility Change (FC)906,

"Containment High Pressure Trip For Feedwater Valves" implemented a single train isolation signaJ for closure of the feedwater valve This was justified by reference to an NRC approved Safety Evaluation

'.. Report issued February 28, 1986, that justified use of a s*ingle train isolation, for another portion of the *same system. * This was based on the low probability of an accident and the high cost required to provided dual train isolation.* This open item documented that the safety evaluation for FC 906 did not address the cost of the modification when authorizing single vers~s dual_ train isolatio The licensee evaluation (RAV 90*058) acknowledged that the cost was not documented in the FC 906 safety evaluation but.still concluded that the single failure isolation signal was valid. This was the *

result of a PRA failure mechanism study for. the system which concluded that system failure was dominated by mechanical failures and not isolation signal failure As a result, a favorable cost-benefit would not be realized by a dual train isolation signal. Based on this evaluation; FC 906 implemented the appropriate isolatio (Closed) Open Item 255/9-0018-Sb(DRP):

Facility Change 906,

"Containment ~igh Pressure Trip for Feedwater Valves," used a previously NRC approved safety evaluation for the containment to justify single failure isolation of the feedwater valves. This open item asked if the licensee was obligated to notify the NRC that the safety evaluation was used to justify additional modification of the system addressed by the safety evaluation. The 10 CFR 50.59 review processes provided the licensee with the NRC notification/approval threshol In this case, that threshold was not exceede No violations, deviations, unresolved or open items were identifie *

. Operational Safety Verification (71707, * 71710, 42700, 60705, 61701)

Routine facility operating activtties were observed as conducted in the plant and from the main control.roo Plant startup, steady power

. operation,. plant shutdown, and syst.em(s) lineup and operation were observed as applicabl *

The performance of Reactof Operator~ and Senior Reactor Operaiors~ Shift Engineers, and Auxiliary Equipment Operators was observed and eva.luate Included in the review were procedure use and adherence, records and logs, communications, shi'ft/duty turnover, and the degree of professionalism of contr61 room activitie~~

Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency *systems, radiation mon-itoring systems, and nuc.lear reactor protection system Reviews of surveillance, equipment condition, and tagout logs were condu~ted. Proper*.return to service of selected comprinents was verifie a~

General The plant began the reporting period.in cold shutdow The licensee

~ompleted the post-outage testing required to return the plant to

. servic At the conclusiori of this reporting period, the plant was in po~er operation at 100 percent powe Plant Shutdown The unit was removed from se~vice, March 24 - March 25, because of a failed level float switch for the "C 11 Safety Injection TanL The failed switch wa~ identified while resolving a ground~ The licensee found that the float to tank cover developed a boric acid leak at a metal to metal seal. This leak eventually resulted in a corroded

switc The licensee decision-to shutdown the plant was conservative because the redundant level monitoring system tends to drift with changes in containment temperattir Evaluation of this repair is discussed in Paragraph ~.c "Maintenance". Criticality The inspector observed the licensee make the unit critical on March 10. This completed the steam generator replacement and started the low power physics testing portion of the startup progra The inspector 1s observations pertaining to *low power: physics testing will be discussed in a future inspection re~ort. In addition, the irispector watched the licensee return the unit to service following the outage discussed in the previous paragrap For both criticalities, the estimated critical rod height and boron concentration were within the predicted target ban *

.

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d. * 50.72 Notiffc~tions *(1)

On February 24, the licensee informed the NRC that during the*

performance of a special test, a safeguard bus low voltag ~ccurred* that resulted in a~ auto start of a diesel generato See Paragraph Surveillance 11 for a discussion of this even The inspector had no additional question Thi~ event will be reviewed when the associated Licensee Event Report is evaluated~

(2)

On February 25, an unplanned reactor trip signal occurred while performing Q0-23, 11Auxiliary Hot Shutdown Panel Instrument Checks.

At the time, all rods were fully inserted into the cor See Paragraph Surveillance 11 for a dfscussion of this even The inspector had no additional questions.* This event will be reviewed when the associated Licensee Event Report is evaluated~

(3)

On February 22, the licensee reported that a personnel error while performing test RT-08C,-

11Engineered Safeguards System -

Left Channel, 11 resulted in a failure of the diesels to start when the wrong fuses were pulled.* Internal corrective action document E-PAL-91-008 addressed corrective action for this even The licensee subsequently determined that this event did not meet the reporting ~~quir~merits of 10 CFR 50.72, 10 CFR 50.73 or NUREG 1022, 11Licensee Event Report System.

As a result, the licensee retracted the 10 CFR 50.72 notification on March 2 The inspector has no additional questions pertaining to reportabi 1 it The inspector did review the personnel errbr aspects of this item and agreed with the licensee tonclusion that the personnel error was the result of an inadequate review of the procedur~

or not havi.ng the procedure 11 in-hand 11 when performing this ste The licensee corrective action was addressed in corrective action document E-PAL-91-00 Additional discussion is contained in Paragraph Surveillance 11 of this report *. The inspector had no additional question The three notifications* occurred in a relatively short time frame and carried a common theme in that they occurred during testin The licensee corrective actions appeared appropriate for each ite In addition, the plant general manager initiated a conference call, on February 27, with Region III Division of Reactor Projects management to discuss the events, to discuss corrective actions and to resolve any questions. *

Low Flow Pretrip During the power increase, a number of Primary Coolant System (PCS)

low flow pretrip actuations occurred above 90 percent powe The licensee secured the power increase at 93.5 percent power and-evaJuated two potential causes. The first was movement or vibration of the core barre During the first operational cycle, core barrel

  • * movement re~ulted in similar actuation~~ Performance bf an. incore

. vibration monitoring surveillance eliminated this from consideratio The second was evaluation. of. the low flow setpoint methodolog The*

new steam generators (SGs) have l~ss flow restriction *. This markedly reduces the differential pressure.(DP) across the SGs which ts the system parameter used to indicate PCS flowrat The past methodology established the DP equivalent to 100 percent PCS flow at the PCS average temperature (Tave) for zero reactor powe This was an added conservatism by the licensee due to SG DP decreasing as Tave increases with increasing reactor powe Momentary fluctuations (noise) in the PCS flow signal had pre.viously been only a small portion of the total flow signa Now, it cori~titutes a much larger proportional change which was causing erratic low flow pretri~ signals. The licensee has revised RI-94, "Reactor Protective System - Low Flow Trip Calibration" to recalibrate the low flow trips at 100 percent power or whenever the pretrips alar The inspector reviewed the safety eval~ation (dated 04/02/91) associated with RI-94 and verified that the new methodology was addresse The* inspector had no additional question Zebra Mussels During the steam generator replacement outage, a small number of zebra mussels were found in the intake piping fro~ the lake to the service water bay.* None were found in the bay. * During the outage, selected-systems that use service water were examined with no fouling identifie On April 1,.the licensee applied for a permit to continuously chlorinate the bay (the bay was previously chlorinated minutes per day).

In addition, the licensee requested perniits to use Betz Clam Trol CT-1 and Nalco Anti-bro Tours (1)

The inspector. routinely toured the containment during the outage and after the containment was certified ready for plant heatup. *

Some tours were performed with members of the plant staff and one tour was performed with NRC Region III Division of Reactor Projects (DRP) managemen Most observations were minor and were resolved when identifie However, the inspector found that tape was used to patch a small crack in the reactor head area ventilation duct. The tape was removed and then reinstalled when it was believed to be part of the ventilation boundar This was discussed with the operations superintendent, who ensured that the tape was removed. - An evaluation was performed to determine if repairs were required immediately or could be delayed to the next outag The repairs were deferred to the

.next outag During one tour, the inspector noted some dirt/dust below a grating next to the 11C 11 primary coolant pump and in other places throughout the containmen The dirt looked like some oil may have been spilled and mixed with it. This was discussed w-ith the licensee at the exit interview, with the suggestion that this be considered during future cleanup activitie *

__ ----

(2)

Tours of the auxiliary-and turbine building.were routinely performe Most were per.for.med without the presence of the licensee staf On separate. *occasions, tours were conducted in company with the Region III Regional Administrator, the Director of the Division of Reactor Projects, the DRP Section Chief, the DRP Branch Chief, and the N~cl~ar Reactor Regulation Region III Project Directo Mino~ obs~rvations were identified and resolve On* one occasion, the.inspector found an ungrounded extension cord plugged into electrical outlet "EL 35-15,".

located on the 611 ft. level of the auxiliary building next to the chemistry lab. This was identified to the shift supervisor who had the extension cord unplugged *. * The next day, the

inspector again found the extension cord in use at the same outleL The inspector discussed this with the safety office, who had a ground plug installed on the extension cor This was discussed at the exit intervie System Walkdown The inspector walked down portions of the auxiliary feedwater system using checklist 12.5 and 12.6; fuel oil system using checklist 22.2; and, diesel generator system using checklist 22.1~

No items were found. that degraded any of the system The inspector did notice that two maintenance supports (one located on the floor and one mounted to the w_all) were in place _at the 11A 11 fuel oil pum Neither appeared to serve a str~ctural purpos~~ In fact, neither was in direct contact with the pipin The licensee was asked if the supports sh~uld be remove No violation~, deviations, unresolved or open items were identifie.*

Surveillance ( 61726, 42700)

The inspector reviewed Technical Specifications (TS) required surveillance testing and special tests conducted during the cold shutdown, hot shutdown, critical operations at low power and power ascension portions of. the

  • restart. The review confirmed that testing was performed in accordance with adequate procedures, that. test instrumentation was properly calibrated, and that the Limiting Conditions for Op'eration were me Additionally, removal and restoration of the affected components were properly accomplished, and test results conformed with TS and procedure requirements, except as individually note The results were reviewed by personnel

other than the individual directing the test and deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The following activities were inspected:

a..

T-302 Emergency Diesel Generator 1-1 Overspeed Trip Setpoint Verification M0-7A.;.2 Emergency Diesel Generator 1-2

~eactor Coolant Pump Delta P Measurement Test Pressurizer Spray Valve Flow Test Atmospheric Dump Valve (ADV) Operatio~al Impact at Hot Shutdown Conditions Step Increase in Power Level High Pressure Safety Injection (HPSI) and Redundan High Pressure Safety Injection (RHPSI) System Functional Leak Tes L MSE-E-21 V_OTES Diagnostic System Operating Procedure for testing and surveillance of motor operated valves M0-3041, M0~3045, and M0-305.

T-305 Atmospheric Dump Valve (ADV) Operational Impact at Hot Shutdown Conditions Test.'. * T-246 Blocked Load Shed on Switchgear Bu~ IC when Supplied by Diesel Generator I-I T-247 Blocked Load Shed on Switch~ear Bus ID when Supplied by Diesel Generator I-2 During ~he*perfor~ance of T-247, the licensee fourid that the breaker for the I-2-Diesel Gener~tor (DG) would not remain in the test position. The test procedure did riot correctly specify the electrical circuit lineup that was re~uired to perform the test.* The test procedure was revised and the test completed satisfactorily.* The companion test T-246 for the 1-1 DG was subsequently performed, with the result that the running Component Cooling Water pumps P-52A and C and the running Service Water pump P-78 t~ipped off when the DG breaker was placed in the test positio As in the previous test, it

  • was determined that the test procedure did not correctly specify the lifted leads or circuit links required to complete the test. The procedure was modified and the test completed satisfactoril The inspector was concerned with the adequacy of the procedure development process since both procedures exhibited inadequacies and the steps required to isolate the loads were different between the tests. The !icensee issued deviation report D-PAL-9I-037 to determine the cause for the problems experienced in T-24 Testing had been successfully conducted with the test procedure in February I987, with no unintended breaker actuations. Subsequent to that time, Facility Change 800 was implemented which altered the wiring for the load shed circuits of both Buses IC and I Initial

review by the licensee of the revised wiring dia-grams indicated tha no modificatiqns to the test procedure were required for isolating-the breakers from a load shed trip~ However, this was not t~ue, as confirmed by further investigation f()llowing the performance of the *

testin *

  • .Q0-28 Auxiliary Feedwater System Cold Shutdown, Inservice Test Procedure During the p.erformance of Q0-28 on "A" and 11C 11 AFW pumps., the inspector walked down Attachment 2 of the procedure, steps for isolating !SI test gauges, with an Auxiliary Operato The following discrepancies were noted:

(1)

On page 2, Attac~ment 2, the wrorig room was designated for

. * location of instruments 727F and 749 They were actually located in the CCW pump ro_om rather than in the AFW pump roo A procedure change was initiated to correct the erro (2) While the ~nstrumen{ isolation valve~ were correctly labeled per the attachment, the vent valves we~e incorrectly labeled and the instru_ment was not labeled: This ~as later corrected by the system engineer when temporary labels were attached to the valves and the instruments until.permanent labels were obtaine (3)

The performance run_ of the 11C 11 pump was satisfactory, but t initial run of the "A" pump was secured due to overheating of packing during venting evolution Following packing adjustments,*

the test was successfully performe. T-303 Emergency Diesel Generator 1-2 Overspeed Trip Setpoint Verification The inspector observed attempts to perform T-303 along with additional steps which were incorporated to allow decreasing engine RPM from 900 to 400 to obtain engine compression reading The compression*

readings were deemed necessary to diagnose differences between cylinder pressures observed during firing pressure tests over the past several years. The following problems were noted:

(1)

(2)

( 3)

Several temporary changes were required to ensure that procedure requirements could be followed step-by-ste On initial decrease of engine RPM, the engine trouble alarm illuminated at about 650 RPM~ due to lube oil pressure falling below 60 ps The operators could not find the controlled copy of the alarm response procedure in its designated position adjacent to the DG rooms, and had to retrieve a copy from the control roo The controlled copy was subsequently found and returned to its correct locatio Following resolution of the alarm condition, the engine RPM was again decrease When the engine reached about 500 RPM, it

  • ,

tripped due to a low lube oil pressure trip (§40 psi).

No further attempts to conduct the low RPM portion of test were mad The overspeed portion of the test was continued arid was s~ccessfully complete The inspector addressed the followi_ng concerns _to the licensee:

Why was compression testing required?

Why did the Minor Revision Notice to the procedure which incorporated the low RPM testing not state th~ reason for including low RPM test?

~ias the licensee's technical review process for the revisio adequate in light of the problems experienced during the test and the additional temporary changes required to enable test performance?

The licensee informed the inspector that compression testing.was considered in discussions between the system engineer and the vendo Problems* con.cerni ng out-of-specif i ca ti ori cylinder pressure *differences were noticed during previous firing pressure testing, and other*

engine analyses had proven to be inconclusiv The low RPM testing was considered as a means to prdvide additional data for assuring

  • engine integrity; and was best performed in conjunction with the overspeed testing. The licensee iridicated that inadeqtiate consideration was given to the other effects on engine performance by RPM reductio The licensee believed that some of the firing pressure differences were due to vibration of a previously-used compression ga~ge, ~nd had recently bought a new gauge to minimize this proble Readings.taken during t~e subsequent performance of ~0-7A-2 using the riew gauge wer~

found to be within the specified pressure differenc p. * RT-013A Normal Shutdown Sequencer Tests - Left Chann~l RT-0138 Normal Shutdown Sequencer Tests - Right Channel During the performance of RT-13A, the first attempt to complete the test was unsuccessfu The contra 1. operator_ qi_dJt.Qt f..u lJy understand that Step 5.3.2 required placing and holding the sequencer test switch in position until all loads were confirmed started. The inspector observed that an explanatory note could have assisted the *

understanding of the operators. The test was subsequently performed correctly by the operators, but difficulties were experiencedwith the data acquisition test rig. This resulted because a drawing, used to connect the test rig, incorrectly identified the polarity for pickup of DC signals. The wiring error was corrected and the test completed.. The system engineer determined that the same error

.existed for obtaining signals for RT-13 The performance of RT-13B was observed to be conducted sattsfactoril RT-08C-RT-080 Engfne~red Safeguards System - Left Channel Engineered Safeguards System - Right Channel lhe ~ns~ector observed-the pretest briefing and control room activities for RT-08C~ The test coordinator was the shift enginee Two control operators (COs) were involved wjth portions of the test to *confirm actuation of ~he battery charger a la r Additionally, they were to perform a switch manipulation in the control room back panels in accordance with the test procedur Originally, one of the two COs was designated to perform the rem_oval of fuses in breaker panel 152~108 outside of the control room to initiate the test.*

Ju~t

_prior td that step, the test director changed the a~signed action to a third C The inspector subsequently observed that this operator was inadequately briefed and did nbt review th~ test procedure,

especially Step 5.3.4, which specified the fuses to be pulled. The

  • operator was accompanied by the electrical test engineer, who assumed

_responsibility for indicating which panel and which fuses were to be pulle However, neither the test engineer nor the operator possessed a copy of the procedur The engineer remembered that he was told to pull the fuses in panel 152-105~ rather than in the correct panel 152-108. The inspecto~ did not observe him reviewing -

the test procedur When the operator pulled the fuses in panel 152-105, a safeguards actuation occurred* as expected, but not due to a loss of off~it~ powe The 1-1 diesel did not start as expected by the test procedure:

All pumps.and equipmerit responded normally but the item was later deemed reportable because the occurrence was *

outside the.expected test para~eters. The licensee issued event report E-PAL-91-008 to determine the root cause of the event -and specify corrective actio The inspector observed that this-was a

- failure to follow procedure along with a loss_ of the command and*

control function by the Ope~ations organizatio The subsequent performance of the test was satisfactory;; as was the performance of the companion test for the other channel, RT-080~

- Q0-23 Alternate Hot Shutdown Panel Instrumentation thecks.

During the performance bf Q0-23 at told shutdown conditions, an unplanned reactor trip occurred due to low PCS flo Two reactor coolant pumps were operating at the time, and the Reactor Protective*

_System (RPS) had been reset to allow turbine testing. The licensee issued event report E-PAL-91-007 to investigate the incident. The trip occurred because Q0-23 did not specify that the low flow RPS trips must be bypasse The procedure inadequacy resulted from the neutron monitoring system engineer's inattention to detail in

- communi eating the effect of FC-829 !t "Nuclear Instrumentation RG 1. 97 Upgrade, 11 to procedure ~ponsors *. It was not recognized that the low

- flow trip bypass was required to perform the testing with less than four reactor coolant pumps operating. Procedures were revised to avoid recurrence of the conditions and operator-training will be conducted to provide understanding cf the circumstances of the even Q0-21

.T-297 Auxiliary Feedwater System Valves, Inservice Test Procedure Diesel Generator 1-1 Load Reject

T-298 Diesel Generator 1-2 Load Reject During the integrated performance of tests Q0-21, T-297 and T-298, *

the inspector observecf local pump, valve, and instrumentation performance and response.. Significant cycling of AFW control valves occurred during portions of the testing which h~ampered* acceptability of control room data for flows *. This occurred due to difficulty in *

setting controller response for this condition of high flow and low steam generator pressure. The test was partially performed again during hot shutdown; with acceptable performance from the controllers and instrumentatio *

The integrated performarice of Q0-21 and T-297 required ~taiting.

the "A" motor-driven auxiliary feedwater* pump following the loading qf the

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1C 11 bus onto the 1-1 diesel generato When this was performed, a momentary undervoltage. occurred on 11C 11 *bus, due to the existing load of a~proximately llOOKW on the bus. The undervoltage condition was low enough to-start the opposite train 1=.2 diesel and.

swapover of the Y-Ql instrument bus to its emergency supply. During the sequence, the Volume Control Tank outlet valve closed but the suction valve to the charging pumps from the Safety Injection and

. Refueling Water (SIRW) tank did not open *. This resulted in the trip of one charging pump on low suction pressure before the SIRW tank valve could be opened by.the operator. Operator responses tothe unarit i ci pated events were satisfactory. *A rerun of T-297 for this porti~n of the test was perform~d and initial conditions were

duplicated except fof placing 1-2 diesel in a run condition~ Data recorders and test personnel were stationed to observe events and operators. were prepared to take necessary compensatory actions. The results of the earlier event were duplicate The overspeed portions of the T-297 testing were performed satisfactoril The licensee evaluated the problems noted during the performance of*.

T-297 under event report E-PAL-91-00 The key findings were as

. follows:

(1)

(2)

(3)

(4)

The voltage drop measured during 1;he test was consistent with.

calculations for the loading conditions~.

The start of DG 1-2 and the transfer of Y-01 was consistent with the measured bus 11C 11 voltage-dro Deenergization of Y-01 results in de-energization of relay 63X/LS-0204, which caused the VCT outlet valve M0-2087 to close and the SIRW tank to charging pump suction valve M0-2160 to ope The relay was normally energized with the contacts for both valves in the open positio Troubleshooting of valve M0-2160 opening circuitry and relay operation confirmed no abnormalitie The licensee concluded that de-energization of Y-01 during the transfer was long enough for the VCT outlet valve contacts to close and 11 sea*l -i However, the contacts for.* the.SI RW va 1 ve did riot.

  • clos*e prior to the relay being re-energized following the transfer~

Since the potentia.l*existed f.or the observed problem during any automatic or manual transfer of Y-01, the licensee replaced relay 63X/LS-0204 with two: relays. These*have a time delay of approximately 2 setonds JUCh that activation Wo~ld not occur during a transfer of

v.. 01 power source Two time delay relays *were required instead of one since a single time delay relay with sufficient contacts could not be found prior to startu Th~ relays were installed unde a Specification Change (SC), SC-91-04 * *

The licensee also addressed probiems with failure of charging pump P-55C to trip on low suction pressure during the original t.est (pump P-55-B did trip). Troubleshooting activities indi~ated inconsistent time delays for the P-55-B suction pressure trip switch; it was replace The 11 C 11 pump pressure switch operated.within specification The corrective action review bo-ard. (CARB) requested System Engineer.ing to evaluate other circuit~ involved in the v~o1 transfer to determine if any others are subject to misoperation of equipment due to momentary deenergization during the transfer * R0-12

. CHP Spray Sy"stem Tests During the perfor~ance of test R0~12, seven components were found in an improper position after the first test on the left channe The test was continued and proper test results were obtained during left ch~nnel test two through test six and during a repeat of test one:

The seven components were reviewed in atcordance with deviatio report D-PAL-91-04 They_were not designed with internal 11seal-in

circuitry to keep them in the closed position once the pressure on the pressure. switches droppe Sea.l-in 11 of the relays for these and other components requires both the activation of a 11 s~al-in

circuit on the relays and closed contacts on the cori.tainment hig pressure reset switc The reset button is pushed after eac~ tes The licensee speculated that the pushbutton contacts-did not pass *

current during ~he initial test but did during subsequeht tests.* The corrective action consisted of replacing the pushbutton switch for *

the left channel containment high press~re reset functio T-186 T-18 T-203 Q0-29 Auxiliary Feedwater Turbine K-8 Overspeed Trip Test and Governor Setting Auxiliary Feedwater Turbine K-8 and Pump P-88 Performance Auxiliary Feedwater Turbine Inlet Pressure Control P-88 Auxi 1 iary Feedwate.r System Pump and Valves Inservice Test Procedure The inspector observed the performance of T-186; T-187, T-203 and Q0-29 for pump P-88, theTurbine Driven Auxiliary Feedwater (TDAFW)

pump.. The tests were conducted successfull The performance was satisfactory to me~t test acceptance criteria. The testing involved feeding steam generators at high flow rates for several minutes to gather the required dat The inspector noted that this led to difficulties in maintaining primary system temperature and pressurizer

.*

pr~ssure due to the steam required to run the TDAFW pump and inje~tion of cold water into the SG At one point,-during the performance of T-203, pressurizer level decreased to the pressurizer heater trip setpoint of 36.percent level (from a starting point of 42 percent).

During subsequent testing with the same operator crew, the inspector observed t~at pressurizer level was increased prior-to test initiation in preparation for the primary system shrink. Additional attention was also* given to charging pump flow rate and secondary system steam discharge (MSIV bypass valves, SG blowdown, etc.) during the testin However, during testing performed severa.l days later, the inspector observed that another shift crew did not prepare the primary system for the shrink. This resulted in pressurizer level decreasing to the

. poi.nt where heater trip was experienced.* The ins_pector discussed the advisability of adding a precautionary note to the procedures with the ~lant operators and the system enginee This wotild draw _

attention to the primary system shri-nk and possible preparations to counteract its effec_ts on equipment operability. A test procedure improvement form.was initiated by the licensee to' incorporate. such advisory notation Summary (1)

' (2)

( 3)

The inspectors observed* control room and field activities, shift turriover and shift briefing activities, and coordination of test activities by Operations test directors. Additionally interactions' between Operations test personnel and system

engineering test engineers, and the perform~nce of Operations

  • personnel during. evolutiohs were observed~ The problems noted with command and* control, adherence to procedures, and attention to procedure*details occurred du~ing the early phases of testing at cold shutdown conditions. These types of problems did not occur during subsequent phases.of testin Indeed, the Operations staff overall exhibited a high degree of professionalism and 11ownersh ip 11 of p Tant equipment and evo lutiOns. The inspector.

observed th~ Plant Operatioris Manager reviewing the w~aknesses observed during the above mentioned event He then communic?lted his expectations for safe and deliberate o~erations with each oncoming shift at shift-briefings. Following these briefings, the inspector observed heightened attention to detail by operators in the conduct of subsequent t~~ts. *

A self~assessment of diesel generator testing and maintenance practices (di~cussed in Paragraph 5e "Maint~nance

) was undertaken by the licensee. Weaknesses were also identified in recognizing the impact of plant modifications on special test procedures and Technical Specification ~urveillance procedures as described in Paragraphs m. and r. abov The licensee con-curred with the need for additional attention to this aspect of test performance and was in the process of addressing a QA audit findirig of a similar natur One factor in the difficulties observed during the*cold shutdown testing phase was the integration of special testing with Technical Specification surveillance testin The specification

.. '

of integration points between test pro~edure~ was performed on the shift ~here the testing was to.be condu_cte This would

~ore properly be a~complished eatlie~ durin~ the planning phase for the test.irlg *. The licensee stated that this consideration would be addressed in futur~ test planning...

No violations, deviations, unresolved or open items-were identifie.

Maintenance (62703, 42700)

Maintenance activities in the plarit were rputinely inspected, including both corrective maintenance. (repairs) and preventive maintenance~

Mechanical, electrical, and instrument and control group maintenance activities were included as availabl *

The focu~ of the inspection was to ensure that the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides, industry codes or standards, and in conformance with Technical Specifications. The followirig items were considered during th~s review:

Umiting 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: The inspector performed* a review and walkdown of maintenance activities a$sociated with replacement of the K-8 steam turbine driver for the 11 8 11 Auxiliary Feed\\'1ater Pump under SC-90-083 and WO 2480174 The work was performed under one work order which was

. open for approximately six month The lic~nsee indicated that, for

  • futute work of this magnitude, consideration would be given to
  • dividing the work into discrete phases. This would allow for easier frillowing of various phases -Of the projec The inspecto~ found that come-alongs had been used to *align the steam inlet pipe with the turbine inlet flang The system engineer.*

explained that adjustment of line hangers (spring cans and rigid *

turnbuckles) was subse~uently performed to bring them within specification and minimize undue stress on the turbine flang No further concerns were identifie *

During hot shutdown testing activities, the turbine driver appeared to perform properly, requiring only minor adjustment During the performance of T-186, leakage occurred at a connection on the turbine casinef drain line to valves MV-FW 510 and MV-FW 861 *. Additionally, the pipe union to steam trap ST-0512 was loose. The pip~ union was successfully tightened, but the threaded joint in the drain line could not be tightened du~ to the downstream piping being welde A work order was initiated to repair the leaking joint, and subsequent operation was successfu * The inspector conducted a walkdown of the 1-2 DG during the 8-hour

. run associated with M0-7A~2. Several vibrating nuts and bolts on

I I

i

.1

cylinder connections to exhaust manifolds were observed. This was identified to the auxiliary operator, who contacted maintenance personnel to review the deficiency for operational impac Work Request (WR) 256345 wa~ initiated to tighten and.torque the observed loose bolts. The WR only identified lbose bolts 6n 3R and 4R *

cylinders, while t.hree were observed (3R, 4R, IL) by the inspector following shutdown of the engine. A fourth suspected loose bolt on cylinder 9L was also not identified. Subsequent review of WO 24101068, after its initial planning, revealed that only the 3R and 4R bolting was ad~ressed. Review of maintenance records back to 1980 for the 1-2 diesel found that no work had been performed on the subject cylinders or exhaust manifold However, a loose bolt had been found previbusly on 1-1 diesel (WO 24901312, March 1989) which had been replace Review of the tech manual for the engine revealed no r~quirements for periodic tightness check of exhaust manifold boltin *

-

The inspector identified the planning deficiency in WO 24101068 to maintenance personne In conjunction with the system engineer, they expanded the scope of the work to include a 11 exhaust manifold*

bolting on both diesels. This satisfactorily resolved the concerns of the inspector. This appeared to be an isolated instance where generic consideration of corrective actions was not applied to other similar equipment during the planning pha~ *

.

. C" Safety* Injection Tank (WO 24101704) did not a*larm at the low level setpoin While evaluating a ground, the licensee determined that the low l~vel float switch for the "C" Safety Injection Tank was inoperable. Boric

_acid had leaked past a metal to metal seal and eventually corroded the switch~ A "blue" check identified insufficient seating surfac The float switch was replaced. A "blue" check of the new float s*witch *

re~ealed sufficient seatin The licensee examined the other tanks

. and confirmed that there was no leakage. Durfog the evaluation, the licensee identified that the work group installing new low level float switches had questioned the fitup of the float to the tan The work group had addressed the questions to the engineer staff, who eventually authorized installation of the float. This was a line item for evaluation on internal corrective action report D-PAL-91-066. * This is an open item pending the licensee's evaluation to determine engineering involvement {Open Item 255/91005-0l(DRP)). Air Line to CV-510, "Main Steam Isolatfon Valvei*- wis leaking_

(WO 2401854).

During auxiliary operator rounds, the operator found a leak at a joint in the copper air line to the air accumulator for CV-051 The licensee determined that a temporary repair was required since loss of air to the accumulator could result in valve closure and a plant trip. The licensee installed a temporary patch and brace and successfully secured the leak. Initially, the WO had authorized the

.installation of-a form and the injection of sealant to stop the ai leak. This was deleted when the patch and brace were found acceptabl The sealant uses heat to solidify and since the air system is at

. ambient room temperature an external heat sburce would be require The ~aintenance p~ocedure -

MSM-M-25~ "R~pair of Gas or_ Liquid Leaks on Non-Q listed Equipment"

~ does not have an applicable section that covers this applicatio In fact, MSM-M-25 only addressed repair of steam leaks *. The WO modified MSM-M-25 to use external heat and specified a maximum temperature* of the form and adjacent pip This was not a procedure change method that was recognized by Administrative Procedure 10.41, "Procedure on Procedures".

The inspector considered this a potential violation of the administrative requirem*ent on procedure changes~ However, by the time the inspector had reviewed.the WO, th~ repairs had been stopped. This was identified to the maintenance department, who modified MSM-M-25 to inc*lude this type of repair.. The maintenance department indicated that this was the only example of a WO making a procedure chang The inspector provided this example to the NRC inspectors performing a maintenance team followup inspection... In addition, this wa discussed at the exit interview. The license~ was encou~aged.to review the planning for the repair activity and to ensure that work planning was not making unauthorized procedure thange The inspector met with plant management on February 22, to discuss the diesel generator maintenance and testing progra Recently, the inspector had observed a number of indicators which may indicate a declining trend. These were:

( 1)

(2)

(3)

(4)

Return to service of Diesel Generator 1-2 with a cylinder fue rack disengage (R~ference Inspection Report No. 50-255/90039(DRP) - Paragraph 4.d.)

  • *

Difficulty in setting cylinder timing for Diesel Generator 1-2 and the return to service of Diesel Generator 1-2.without priming the fuel lin Testing problem~ a~sociated with both diesel generators while performing. T-246 'and T-24 (Reference Paragraph 4.m,

11Surveillance 11 of this report.)

Incorporation of the requirement into T~303 to obtain engine compression readings without considering the effect on the machin (Reference Paragraph 4.o, 11 Surveilla~ce" of this report.)

As a result of this meeting and other observations made by the licensee, a task force was formed to provide an independent assessment of retent diesel generator maintenance and testing practice The primary results were discussed with the resident inspectors and are documented belo Question Is there a trend in the failure to return diesel generators to service following maintenance?

The task fore~ concluded that a trend was not readily apparent. Management's practice was to minimize diesel generator starts by combining post maintenance and

  • operability testing. Combining this practice with the low threshold for a corrective action document could give the appearance of a trend:.

The inspector agrees and has no more questions.

. Question Are the diesel generator maintenance documents Question. matched to the *skills of th~ workers?

The task force concluded that the skill of the workers and procedures are not matche Apparently, the diesel generators' high reliability was the combined effect of System Eng.ineers and maintenance. schedulin The task force determined that training by the vendor had not been conducted

  • in a number of years.* This has resulted in only a few trained_workers still in the department. A number of recommendations were made to improve performanc At the exit interview, the licensee was reminded that the skill of the craft and the technical level of the procedure must be matche If not, the procedures required by Technical Specificatidn 6.8 by reference to Reg Guide 1.33 are not adequate and the licensee is.in violation of Technical Specification In
  • addition, the licensee was reminded that a declined rating in Emergency Preparedness in SALP 10 was partially due to lack of trainiri. -

Are the testing procedures technically adequate?

The task force found that the Technical *specificatio~

surveillance tests are adequat Howeve~, the special tests appear to be lacking some of the precautions necessary to perform them.. It appears that. the

.

Technical Specification tests get a different review than the special tests d The inspector notes that this observation applied to other special tests as evidenced by the problems discussed in Paragraph 4,

"Surveillance 11 *

The task force conclusions appear to address the inspectors concern Evaluation of the licensee response to these concerns will be

.

observed as part of inspector's routine maintenance and surveillance obs_ervat ion No violations, deviations, or unresolved items were identifie One open item was identifie.

Design Changes (37700)

From the-beginning of restart testing through initial power ascension, the inspector observed plant conditions related to the replacement steam

.. *

~

generators arid aisociated modtficatton activities. These observations and testi_ng results were. discussed with Operations and _System Engineering personnel. It was noted that control rod.drop times were not affected by the increased reactor coolant flow, and total PCS flowrates were within expected values.* The higher PCS flow-resulted in increased sensitivity of the differential pressure instrumentation for detecting low PCS flo Th~

  • adjustmerit of the low. flow pre-trip a la.rm. setpoints for the RPS to avoid spurious alarms was discussed in Paragr~pn 3.e, 110perationa l Safety Verification."

PCS leakrates were very low indicating good integrity of the primary system The ease of establishment of initial condenser vacuum indicated a high degree of leaktightness *. Transient test results *

(T-305 and T-306) indicated adequate response of steam generator level * *

controls without unanticipated transient response *

.

.

  • The inspector reviewed other facility changes ( FC) and observed the following ~eaknesses: During the performance of Q0-21, the inspector observed the 11valving-in 11 of local instruments which were installed under FC-847 *

during the last refueling outage for collection of !SI dat When gauge FI-0737A was 11valved-in 1', the operators and the inspector noted that the instrument went'offscale lo Inspection of piping to the instrument revealed that the high side and the low side piping were reverse *

The inipector discussed FC-847 with the licensee and reviewed construction drawings 8-JG~177, Sheet 24, Revisions 1 (7/29/89)

and 2 (1/9/91).* Revision 1 was released prior to installation, *

and Revision 2 was released after installation to incorporate field

. change The FC was in the final process of construction closeout prior to turnover to Operations. The local instruments were installed by tapping existing instrument lines from Flow Elements FE-0737 and FE-0736 to FT-0737A and FT-0736 The inspector noted that the drawings were partial isometrics with just enough detail to allow installation of the gauges. Several configuration errors were noted on the drawing Ohe error was a reversed flow configuration *

for FE-0736 and associated instrument piping; this error was present on both Revision 1 and Revision 2 of the drawin The other error was an_ incorrect valve number for instrument root valve FW-631A (in~icated as FW-637A) on Revision 2 of the drawing; the valve was corre~tly identified on Revision The-inspector questioned whether there was a construction error associated with the installation of FI-0737 He was informed that the constructor*possibly identified the proper tapoffs through reference to the instrument root valves without regard to flow

direction. If so, the installation for FI-0736A'was correct in spite of the drawing erro In regard to FI-0737A, deviation report D-PAL-91-053 not only identified the installation error but also noted that the instrument root valve tags were interchange If the constructor had keyed off the root valve tags, this could have resulted in the erroneous installation. However; the constructor could net confirm that this was actually the cas * *

The review of this FC showed a lack of configuration control for

. the subject drawings, and weaknesses in post-work walkdowns by the license The licensee had not identified the interchanged valve tags or the improper piping for g~uge FI-0737A~

The inspector also learned that rework was required on two other ISI instrument installations under the same F These were the LPSI system, DPI-0323, P-67A Differential Pressure and DPI-0322, P-678

  • Differential Pressur The responsible engineer for the FC was contacte The engineer informed the inspector that the original design intent was to provide an isolation valve to the local instrument. This would allow local instrument isolation without
  • rendering the control room differential pressure gauges inoperabl However, construction drawings prepared by engineering designer did not include the necessary isolation valv The discrepancy was not realized ~ntil walkdowns were conducted during the present refueling outag No deviation report was issued for this conditio The inspector discussed the lack of a deviation report with plant management indicating that installation instructions were issued that did not actually reflect the intended design. A deviation report was issue On March 7, the inspector reviewed the hot shutdown testing portion of test procedure T*FC-685-001 for*the anticipated transient without scram (ATWS) trip modifications performed under FC-68 The inspector informed the Project Test Supervisor that a modified test procedure did not satisfy the purpose of the.test. The acceptance criteria 6. 2.1, states that "The effect bf the. ATWS/auxil iary feedwater actuation signal (AFAS) modification on starting pump P8B has been successfully tested during hot shut.down.*..

The Project Test Supervisor suspended the test and confirmed that activation of the ATWS solenoid valves (SVs) was require EDC-30 was issued to revise the test procedure and the test was successfully conducte The purpose of the hot shutdown testing was to confirm proper operation of TDAFW control valve CV-05228 and TDAFW pump under simulated ATWS condition The licensee previously performed a functional test of the system on Fet>ruary 1 Valve opening stroke times were measured to determine if flow control valve CV-0522F was properly set. Closing stroke times determined if a check valve, located in the connecting line between the existing solenoid valve SV-05228 and SV-0522C exhaust ports and the new solenoid valves SV-0522G and SV-0522H installed for the ATWS actuation, unduly lengthened valve closur The check valv~ was designed to direct air flow from the ATWS solenoid valves through separate piping from the existing system upon actuation, but allow blowdown of the air through both sets of solenoid valves during closur Based on the results of the co1d shutdown testing, the AFW system engineer requested that the check valve between the two portions of the system be removed to minimize rundown time of the turbine driven AFW pum EDC-27 was prepared to remove the check valve from the interconnected systems and close flow control valve CV-0522 This

  • .
  • , *

resulted *in the elimin~tion of ihe separate path from the output of the ATWS SVs to the input of CV-0522 EDC-2~ was also issued in the same time frame to modify the ATWS test procedure for hot shutdow Valve opening ~nd closure times were measur~d through actuation of the mahua-1 handswitch on the control board~ rather than by pulling DC control power fuse The ori~inal intention was to cause activation of the ATWS SVs by pulling the fuses~ The inspector a.lso noted an administra~ive weaknes Engineering and QA had signed EDC-27 on February 1 Signatures indicating approval by the SRO/PRC Member and Administrative Review and Approval were e>btained by telecon on March 6, just prior to performing the modification to remove.the check valv *

The inspector reviewed the control room "redline 11 print for control air to CV-05228 (M-205, Sheet 2, Revision 27)~ on Maich ~-

It had not been corretted for the change implemented through EDC-27 on March 6, 199 The Document Control Center drawings had also *no been revise The litensee corrected.the drawings and issued deviation report D-PAL~91-060 on March 13. This addressed the missed revisions and the concern for any additional discrepancies between installed modifications and plant critical drawing The observations above confirm a continued weakness in *the area of

  • attention to detail on the part of the engineering design organization, consistent with.the findings of the recent SALP cycle 10 repor On March 15, Consumers Power Company announced the formation of a new design engineering organization and a new department responsible for the Quality Assurance audits and the off-site review functio This change was licensee initiated and intended to improve plant performanc The new department heads were Consumers Power employee The design engineering organization will be located at the Palisades sitei Both departments will report to the Vice President for Nuclear Operation To support the formation of *the new departments~ a number of organizatio~ realignments and personnel changes were mad The r~organization is to be discussed during a Consumers Power and Region III Management meeting at Region III Headquarters on April 1 No violations, deviations, unresolved or open items were identifie. -

Regional Initiatives (71707, 71710) Containment Sump In response to a request from Region III management, the inspector reviewed licensee records to confirm that the containment sump had been cleaned and inspected as required during the refueling outag Review of Work Order 24002149 indicated that the sump was cleaned and inspected on February 20-21, 199 *

  • Containment Hydrogen Recombiners In. response to a request from Region *1 II management, a review of the design and o*peration of the licensee's hydrogen recombiners was conducte *

Post-LOCA hydrogen control at the Palisades Piant is assured by two

  • 100 percent redundant and independent electric recombiner unit Each unit contains an ~~ectric heater-bank and was located inside of the containment building. The associated class IE power supply panel and control panel for each unit were located in the cable spreading room of the auxiliary buildin *

The electric hydrogen recombiner system i.s essentially a passive safeguards system with no moving parts. Following a LOCA, operation of the recombiner units is initiated from the conttol pane Containment atmosphere is drawn through the units by natural convection, caused by the high temperature of the heating element The afr temperature in the unit is raised, and the recombination of hydrpgen with oxygen occurs. A more detailed description of the system is in the Final Safety Analysis Repor The Limiting Conditions for Operations and the associated surveillance requirements are addressed by Technical Specification 3.6.4. and Table 4. No violations, deviations, unresolved or open items were identifie.

Management Interview The inspectors met with licensee representatives - denoted in Paragraph 1 -

on March 15 and April 16, 1991 to discuss the scope and findings of the inspectio In addition, the likely informational content of the

inspection report with regard to documents or processes reviewed by the inspectors during the inspection was also discusse The licensee did not identify any such documents/processes as proprietar Highlights of the exit interview are disc~~sed below: Strengths noted:

(1) Conservative action to remove the unit from service-when a Safety Injection Tank level float failed {Paragraph 3.b, (2)

(3)

(4)

110perations 11 ).

  • -

* --n*

-

~illingness to secure a power increase and resolve primary coolant system low flow pre-trip actuation {Paragraph 3.e, 110per_ations").

Overall Operations pt:ofessionalism and ownership of plant equipment and evolutions (Paragraph 4.v.(1), "Surveillance").

Involvement of Operations management in stressing adherence to correct operating practices (Paragraph 4.v.(1), "Surveillance").

. i

.

. Weaknesses noted:

(1) Operations procedure adherence tna~equacies (Pa~agraphs 4.p, 4.q,

"Surveillance").

(2)

Inadequate incorporation of plant modifications into surveillance and special tests (Paragraphs 4.m, 4.r, "Surveillance").

(3) * Inadequate development and review of test procedures a~d pro~edure r~visions (Paragraphs 4.m, 4.n & 4~o "Surveillance").

(4) Weaknesses in integration of special and surveillance testing activities (Paragraphs 4.u & 4.v.(3), "Surveillance", summary).

(5)

Inadequate maintenance planning to resolve defitierit equipment conditions (Paragraph 5.b, "Maintenance")..

  • .

(6)

Procedure modification by the work order (Paragraph 5.d,

"Maintenance").

..

(7)

(8)

..

( 9)

Inattention to detail in modification design and inadequate *

walkdowns of modification installations (Paragraph 6.a, "D~sigh Changes").

.

.

..

La~k of configuration control (Paragraphs 6.a, 6.b, "Design Changes" L

. *

. *

._

.

.

.

Inadequaie modification test pr~cedu~es (Paragraph 6.b, "Design Changes").

. * The 50.72 Notifications were discusse Two of the notifications will have additional reviews when the licensee event reports are reviewed (Paragraph 3.d., "Operations").

  • The licensee was asked to evaluate remov~l of potentially oil soaked dirt/dust from the containment during the next outage (Paragraph 3.g.(l), "Operations").
  • The open item (Paragraph 5.c, "maintenance") was d~scussed. This item sho~ld be resolved when the deviation report is close
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