IR 05000255/1991010
| ML18057A947 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/30/1991 |
| From: | Phillips M, Yin I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A945 | List: |
| References | |
| 50-255-91-10, NUDOCS 9106050049 | |
| Download: ML18057A947 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/91010(DRS)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades site, Covert, MI 49043 Inspection Conducted:
April 30 through May 2, and May 6-9, 1991 Inspector:
Approved By:
<<~
~
Monte P. Phillips, Chief
- -Operational Programs Section Inspection Summary Date
~/~o/r; Date Insoection on April 30 through May 2, and May 6-9, 1991, (Report No. 50-255/91010(DRS))
.
.
Areas Inspected:
Routine, announced inspection of licensee Configuration Control Program (CCP) implementation, follow-up of mechanical engineering issues identified in NRC Inspection Report (IR) No. 50-255/90010, review of the newly issued Design Basis Document (DBD) Writer's Guide, review of the re-write-of the Component Cooling Water (CCW) System DBD, and review of corrective* actions conducted by CP for some of the significant deficiencies identified under the CCP progra Results:
Based on a review of these areas the inspector concluded the following: The licensee's Design Basis. Documentation (DBD) -Writer' Guide covered adequate technical areas and provided the writers with sufficient instructio The examples provided in the Guide were useful but lacked provisions for each of
.the mechanical, electrical, and structural engineering disciplines.
9106050049 910530 -
PDR ADOCK 05000255 G
.
- 0 The revised DBD for the ccw system was technically sound and acceptabl The issuance of the DBD for the CCW system did not result in updating of all relevant design, operation, maintenance, and regulatory document *
- DETAILS Persons Contacted Consumers Power Company (CP)
- W. L. Roberts, Licensing Engineer
- D. J. vandeWalle, Engineering Programs Manager
- K. A. Toner, Electrical, I&C, Computer Engineering Manager
- R. D. Orosz, Nuclear Engineering and Construction Manager
- B. Harshe, Supervising Engineer Millican and Associates
- J. A. Blewett, CCP Project Engineer U.S. Nuclear Regulatory Commission J. K. Heller, Senior Resident Inspector
- Indicates those attending the exit meeting at the site on May 9, 199 Other licensee personnel were contacted as a matter of routine during the inspectio.
CCP Completion Status and Open Items During the performance of the CCP, the licensee identified discrepancies that were categorized into three area Discrepancies in the first category were considered to be minor and would be corrected as part of the CC These discrepancies were associated with drawing errors or other minor condition The second category related to issues that had not yet been characterized as to their significanc These issues involved areas where additional information was needed to determine if the discrepancy was minor (Category I) or major (Category III).
Additional action was required by the licensee to evaluate these issues for transfer either to category I or category II The third category was major discrepancies which, in most cases, involved a change to the facilit Findings in this category were placed into the licensee's normal corrective action system with the issuance of a deviation report (DR).
As of April 26, 1991, the licensee had completed the following system evaluations:
- a.
ccw sws AFW CR-HVAC HPSI LPSI *
Mechanical/NSSS DBDs Report Cat. I Cat. II Cat. III Appo Issuance ident./
ident./
ident./
Start Date Date Closed Reclass*
DR issued 03/01/88 05/04/89 49/45 36/34 2/2 01/01/89 08/10/90 10/6 25/7 1/1 06/01/89 07/19/90 6/1 13/1 0/0 01/01/89 07/19/90 4/0 20/10 1/1 01/01/89 06/15/90 3/1 16/3 0/0 11/01/89 12/17/90 4/4 16/2 1/1 Total 76/57 126/57 5/5
- Of the 57 category II items that had been reclassified, 56 became category I items and one became a category III ite Electrical -
Emergency Power DBDs Report Approx Issuance Start Date Date Diesel Generator Perf orroance 01/01/89 09/18/89 Emerg Gen & Gen Prat 01/01/89 09/18/89 Sequencer (NSD/DBA)
03/01/89 02/01/90 Load Shed 08/01/89 05/30/90 Station Batteries 09/01/88 09/18/89 125V DC (Safety-Related)
06/15/89 01/26/90 Pref erred AC 06/01/90 11/29/90 2400V AC 04/01/88 12/20/88 2400V AC (Rev 1)
11/01/90 03/11/91 480V AC 04/08/88 12/20/88 The DBDs documented a total of 17 category I items of which nine were closed; five category III items of which all had DRs issued; and 53 category II items of which 21 had been reclassified (20 became category I items and one became a category III item).
c. Electrical - Station *Power DBDs Report Appro Issuance Start Date Date UPS 06/01/90 02/13/91 4160V AC 04/01/88 11/18/88 External Pwr Xfmrs 02/01/88 12/13/88 Instrument AC 02/07/88 12/19/88 CRD Power 08/01/88 12/19/88 CRD Power -
Rev 1 09/01/90 02/13/91 The DBDs documented a total-of 24 category I items of which 18 were closed; one category III item with a DR issued; and as* category II items of which 51 have been reclassified (49 became category I, and two became category III items).
Safety System Design Confirmations (SSDCs)
Ca Cat.II Start Issue * ident. / ident. /
Date Date Closed Reclass.*
ccw 4/5/89 6/28/89 16/14 4/2 4160v AC 8/1/89 10/17/89 10/9 1/1 Batteries &
DC Power 1/15/90 3/23/90 15/11 4/3 sws 4/9/90 5/25/90 16/14 0/0 LPSI/HPSI* 6/18/90 8/03/90 9/8 1/0 2400v AC 12/3/90 2/8/91 18/1 /0 Totals 84/68 16/6
- All of the six category II items have been reclassified as category I item Cat.III ident/
DR Issued 5/5 2/2 8/8 3/3 0/0 0/0 18/18 The closing of category I items was by means of issuing work requests~ procedural change requests, or change of design document One of the issues identified in NRC Inspection Report (IR) 50-255/90010 was that an excessive number of category II items had not been evaluated for final categorization in a timely manne The above Category II data showed significant improvement from the time of the previous NRC inspectio This issue was considered resolve *
3 *
CCP Completion Schedule The completion of the CCW DBD Revision 1 was in April 199 The licensee decided to defer the Safety System Design confirmation (SSDC) effort for the ccw DBD from Fall 1991 to either late 1991 or early 1992 as documented by a CP internal memorandum, dated August 10, 199 The inspector reviewed the reasons given and,agreed with the licensee's*
decisio The schedule and resources for the ccw SSDC was allocated to the performance of the SSDC for the 2400V DBD which started on December 3, 1990, and was completed on February 8, 199 The inspector reviewed the recent CP plan dated April 26, 1991, concerning the schedule and scope for the remaining ssocs:
The_CCP completion schedule (second quarter of 1993) appeared to be unchanged from that given to the NRC during the last licensee update meetin.
Mechanical systems walkdown NRC IR 50-255/90010 raised a concern that there was a lack of walkdown verification for the mechanical portion of the CCP program. - During this inspection, the licensee provided a written clarification of their program scope and rational The scope *of both the DBD and SSDC was principally design basis oriente As such, neither effort incorporated formal walkdowns of the systems and both efforts relied primarily on review of plant design records and documentatio The SSDC did include a system. familiarization walkdown against the piping and instrumentation diagrams (P&ID) to identify maintenanc;::e status and operational.concerns related to the design as well as to familiarize the SSDC-team members with the layout of system component Formal system walkdowns were not included in the scope of the DBD and SSDC since the licensee had performed walkdowns previously as part of other activities, such as pipe support verification associated with NRC Bulletin 79-13, operation-oriented P&ID walkdowns, walkdowns associated with the valve improvement team, and the CCP equipment database verificatio These verification efforts did not identify significant-discrepancies between the drawings and-field conditions; therefore, the licensee planned to perform walkdowns only to. resolve conflicts that could not be resolved based on a document search, or if major modifications had been mad Subsequent to the last NRC CCP inspection*, a detailed walkdown of the Service water System (SWS) was conducted to support the sws SSDC and the response to NRC Generic Letter 89-1 This walkdown also identified no significant discrepancies between the field configuration and the system P&ID The inspector had no adverse comments regarding the planned scope of walkdowns associated with the CC.
Licensee Inspection of ccw Heat Exchanger Tubes NRC IR No. 50-255/90010 raised a concern that the specific cause of the tube degradation had not been determine During the plant outage in 1990, CP performed an eddy current inspection of CCW heat exchangers (CCWHXs) E54A and E54 A total of 500 tubes were inspected for each CCWHX covering all cross-sectional region The results of the inspection showed that all wall thinnings occurred at the first eight rows near the CCW flow inlet nozzles. *There were no signs of severe silting and scale buildup on the bonnet The tubes had a slight film buildup along the length, which was removed during cleanin Two tubes in CCWHX E54A and eight tubes i.n CCWHX E54B exceeded the 40%
wall degradation limit and were plugged with full length rod At the conclusion of the inspection there were 98 plugged tubes in CCWHX E54A and 95 in CCWHX E54 The CP engineering analysis showed that a total of 202 tubes could be plugged before effecting required heat removal capability under design basis accident condition The licensee inspection also concluded that the tube degradation was 1caused by flow-induced vibratio The cause of flow vibration is discussed.in Paragraph 7 The licensee planned to expand inspections for the first eight rows of tubes near the flow inlet and trend the indication result The inspector considered the licensee actions acceptabl.
DBD Writer's Guide One of the reasons why the licensee decided to re-perform the DBD for the CCW system was that the previous DBD was lengthy and raised too many questions rather than providing design bases and associated justification informatio The cause of the problem was attributed to the lack of guidance for the authors; particularly instruction on what specific technical data and documents were to be collected, assembled, reconstituted, and justifie The inspector reviewed the Palisades Nuclear Power Plant
"Writer's Guide for Preparation of System Design Basis Documents," Revision 1, approved on April 8, 199 The coverage was extensive and the guidance provided was clea The examples given in the guide were relevant and useful; however, they were not comprehensiv Some examples demonstrated mechanical applications; some demonstrated electrical applications; and a few demonstrated structural application.
Review of ccw DBD The inspector reviewed CP DBD-1.101, "Palisades Design Basis Document, Component Cooling Water System," Revision 1, dated April 199 Although the document had not formally been released at.the time.o-f* this inspection, it had been reviewed and approved by CP technical managemen Based upon the review, the inspector had the following comments: The ccw DBD, Revision 1, was based on.the DBD Writer's Guid The report was technically sound and contained valuable design bases and evolution informatio However, two formatting areas may be worthy of licensee attentio First, the technical information for one specific subject was spread into many areas making reading a difficult tas For example, under Section 3.1.1., the CCW system flow margin was referenced as being in Table 5-2, which then referenced Appendix E, Open Item 30 for individual component required flows, which then referenced test T-223, Revision 2, for accident condition flow This test report had not been issue The inspector felt that if the format was. to remain unchanged, at least page numbers for all the references should have been provided in the repor Second, there was an abundant use of system and functional abbreviations throughout, but there was no section to define *the This lack of a section describing abbreviations made reading of the document difficult, e.g. Recirculation Actuation Signal (RAS) and Containment High Pressure (CHP) was explained only once under Section 1.2; System Boundaries, in the last paragrap The required ccw flows under (1) normal plant operation at 100% power, (2) normal shutdown cooling (SDC),
(3) Accident Safety.Injection Signal (SIS), and (4) Accident Containment High Pressure (CHP), and Recirculation Actuation Signal (RAS) have gone through a number of evolutions as follows:
Required ccw Flow Cgpm)
Norm.
Nor Acci Acci. Document O SDC SIS CHP/RAS Original FSAR 3,798 10,714 190 8,190 DBD, Re,256 7,319 5,805*
5,093
- Since there was no provision to isolate components, such as the shutdown Cooling Heat Exchanger (SDCHX)
(5000 gpm) and Primary Coolant System (PCS) pumps (360 gpm), the total flow was much more than originally require The associated Component Cooling Water Heat Exchanger (CCWHX) capacity has gone through a number of
evolutions as wel The original maximum design capacity had been specified as 11,340 GPM in specification 5935-M-1 However, the vendor had supplied a 13/16" tube pitch instead of the specified 15/16 11 pitc As a result, the heat exchangers had experienced significant vibration, and in 1986 the licensee specified that the maximum flow rate be reduced to 5,700 GPM to reduce vibratio This was subsequently raised to 9,400 GPM in 1989 based on a flow analysis performed by YUB The capacity of the CCWHX was sufficient for all of the above required CCW flow In 1986, the licensee performed CCW flow balancing to meet the required normal and accident CCW flow requirements under various system alignment During the last plant outage in 1990, flow balancing arid testing was again performed using special procedure T-22 The emphasis was placed on the worst accident condition (CHP/RAS) with *only one CCW pump runnin The inspector reviewed the preliminary test results and observed that adequate flow was delivered to all required equipment, such as shutdown cooling heat exchangers, charging pumps, and various safety injection and spray pump The CCW DBD, Revision 1, design requirement was verified by the test.. *
NRC IR 50-255/90010, Paragraph 2 noted that there had been a lack of design control in the past for the Palisades plan As the DBDs were being completed, there appeared to be a need to void or update most, if not all, of the revised design values, and review all of the affected operational and maintenance procedural requirements and acceptance criteri However, the CCW DBD, *Rev.-- 1, stated *in +/-ts foreword, that "'It is intended to supp*ort rather than replace information contained in other documents such as the FSAR, functional system descriptions, TSs, etc."
The inspector discussed the need for the licensee to develop a program for resolving conflicts between the DBD and technical and regulatory documents, voiding of design errors; and updating or revising system design and/or functional conditions.
9 Licensee Corrective Actions The inspector selected three category III items (two from the ccw SSDC, and one from the SWS SSDC), and one category II item from the CCW SSDC for follow-up of licensee corrective action The category III items were tracked
under CP Deviation Reports and the category II item was tracked under a Discrepancy Repor D-PAL-89-122 CCCW)
This DR was issued on June 22, 1989, and was closed on July 5, 198 The DR documented the following deficiencies:
(1) the two CCW *containment isolation valve actuations did not have low pressure alarms; (2) a valve test showed that the required valve closure air pressure differed from vendor data, (3) valve closure tests were performed under no flow conditions, and (4) there were no procedures to direct operations to normally close the valves on low air pressur The inspector reviewed the licensee's corrective actions and technical evaluation and considered them to be adequate except for one are Operation procedure No. CNP 7.1, "Loss of Instrument Air," was revised on November 14, 1989, to require an operator to manually close the two ccw Containment isolation valves when instrument air pressure fell below 75 psig for 30 minutes and when CCW containment isolation was require This procedure change'was determined by the CP operations management to not warrant immediate trainin The training was not scheduled for the operators until July 1991, almost two years after the procedure had been revise * D-PAL-89-123 {CCW)
This DR was issued on June 22, 1989, and was closed on July 25, 198 The DR stated that the new inlet air check valves to one of the twoccw containment isolation 'valve accumulators were not leak tested at the proceduraly specified pressur The procedure
- required a ~pressure of 110 "psig, but the test was done at 100 psi The inspector reviewed the licensee's evaluation to accept the test and had no adverse comments.*
10 D-PAL-90-170 (SWS)
This DR was issued on June 21, 1990, and corrective actions were still underwa The DR documented that six sws pump output header isolation valves were not stroke tested in accordance with ASME Section XI Cod These valves have been stroke tested in a separate program in the past, but it did not include specific stroke time and test frequency as required by the Cod The inspector reviewed licensee documents including root cause analysis, engineering recommendations, maintenance program update, valve test procedure update, and technical specification surveillance procedure update, and considered the planned corrective actions to be adequat F-CG-89-124 (CCW)
This SSDC Category II discrepancy report was issued on June 21, 1989, and had not been re-classified as either
- category I or III at the time of the inspectio The report stated that CCW system inventory could be lost after a failure of non-seismic piping inside containment coincident with containment isolation valve failure to open due to loss of off-site power thereby making the plant air system inoperabl This specific concern and others were reported to.the NRC in LER 89-066-01 on September 19, 198 The licensee stated that the issue did not get re-classified because the technical evaluation was covered in the CCW DBD, Revision 1, which was not completed until April 199 Based ori the high energy line break (HELB) analyses inside containment completed in March 1990, and the CCW DBD report finding, the licensee stated that the item was now considered to be a category I item, and would be closed upon formal issuance of the DBD report.,. The inspector concurred with the licensee's resolutio..
Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1) on May 9, 1991, at the Palisades, Nuclear
,
Generating Plant and,summarized the purpose, scope., and" findings of the inspectio The inspector discussed the likely informational content of the documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents or processes as proprietar