IR 05000255/1991014
| ML18057B233 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/23/1991 |
| From: | Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057B232 | List: |
| References | |
| 50-255-91-14, NUDOCS 9109040178 | |
| Download: ML18057B233 (13) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I II Report No. 50-255/91014(DRP)
Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, MI Inspection Conducted:
July 2 through August 12, 1991 Inspectors: J. K. Heller J. R. Roton E. R. Schweibinz Approved By:~~ief Reactor Projects Section 2A Inspection Summary Date Inspection on July 2 through August 12, 1991 (Report No. 50-255/91014 (DRP))
--
Areas Inspected:
Routine unannounced inspection by the resident inspectors of actions on previously identified items, plant operations, reactor trips, maintenance, surveillance, and Bulletins and Generic Letter No Safety Issues Management System (SIMS) items were reviewe Results: No violations or deviations were identified in any of the six areas inspecte Two unresolved items were identified. The first pertained to between-the-seal testing of the containment escape airlock (paragraph 2.f) and the second involved operator response to a feedwater transient (paragraph 3.d. ).
Strengths, weaknesses and open items are discussed in paragraph -9, "Management-Intervi ew."
In summary: the plant response to the two reactor trips was uncomplicated; operators demonstrated good plant knowledge when responding to plant transients; communication (within the plant organization and to the NRC)
was mixed with examples of good and bad performance; and, plant cleanliness has declined in some areas of the plan PDR ADOCK 05000255 Q
DETAILS Persons Contacted
- G. B. Slade, Plant General Manager
- R. M. Rice, Plant Operations Manager D. J. VandeWalle, Engineering Programs Manager
- P. M. Donnelly, Safety & Licensing Director K. M. Haas, Radiological Services Manager J. L~ Hanson, Operations Superintendent
- R. B. Kasper, Maintenance Superintendent
- K. E. Osborne, System Engineering Superintendent C. S. Kozup, Technical Engineer W. L. Roberts, Senior Licensing Analyst R. W. Smedley, Staff Licensing Engineer
- Denotes some of those present at the Management Interview on August 14, 199 Other members of the plant staff and several members of the contract security force were also contact~d during the inspection perio.
Actions on Previously Identified Items (92701, 92702) (Closed) Violation 255/86028-0l(DRP):
Design changes not reflected in drawing This violation was administratively closed in accordance with NRC Region III procedures, as identified by the Director, Division of Reactor Safety, in his memorandum dated January 7, 199 (Closed) Violations 255/89027-01, -03 and -04(DRP):
Licensee violated containment integrity requirements (Technical Specifications 3.6 and 1.4) for approximately 10 years while performing various repairs and tests to valves and instrumentation associated with containment penetrations 17 and 4 The licensee response, dated January 25, 1990, was reviewe The inspector verified that the following actions were completed: formal training was provided to electrical, mechanical, and I&C repair
_________ p_ersonn_e.l,_ ao~_:t_o_EPPlicable engineering staff, covering the requirements of 10 CFR 50 Appendix-J;--I&C-caTfbra-tion ___ procecfures--were-upgraded to--- --- - ----
more clearly define the containment boundaries; and, the Human Performance Evaluation System (HPES) was utilized to determine the root cause of performance problems pertaining to review and approval of surveillance procedure (Closed) Violation 255/89027-02(DRP):
Licensee violated Technical Specification 4.1 and 10 CFR 50 Appendix J by not verifying the integrity of containment penetrations 17 and 48 subsequent to modifications performed in 1980. A local leak rate test (LLRT) was not performed on a portion of the piping until July 28, 198 * The licensee response dated January 25, 1990, was reviewe The inspector verified that LLRT procedures were instituted to provide continued testing of all piping associated with penetrations 17 and 48 in accordance with 10 CFR 50 Appendix J and that a complete review of the integrated leak rate test {ILRT) and LLRT programs was complete (Closed) Open Item 255/89028-02(DRP): Pressurizer Code Safety Failed To Meet Its Acceptance Ban This open item was written to evaluate the licensee's long term corrective progra The licensee has submitted a Technical Specifications change request to increase the setpoint toleranc In addition, the licensee contracted an overhaul by the vendor when the valves were removed and sent off site for testing. During the 1990 refueling outage, the valves were tested with satisfactory result (Closed) Open Item 255/89031-0l(DRP):
Inconsistencies In The Installation Of Electrical Canisters In Containment Penetration The licensee performed an evaluation which was documented on Action Item Request 90-1 The analysis concluded that the 11as found" condition was not in conformance with the FSAR, however, the configuration did not create an operability questio The document discrepancies were reconcile (Closed) Violation 255/89009-0l(DRP):
Failure To Perform A Between-The-Seal Test of the Containment Escape Airlock. This item was previously closed in Inspection Report No. 50-255/90021(DRP).
This write-up updates the actions taken to resolve the violatio NRG Inspection Report No. 50-255/89009, contained a Violation involving the licensee's failure to perform a between-the-seal test of the escape airlock door within three days after door usage in accordance with 10 CFR Part 50, Appendix J, III.D.2.(b)(iiiJ. The licensee's written response, dated May 22, 1989, acknowledged that this type of testing had not been completed due to the escape lock physical design configuratio By letter dated June 30, 1989, the licensee described an alternative test (seal contact check) to a reduced pressure between-the-seals tes The NRC Office of Nuclear Reactor Regulation (NRR) initiated TAC
- --- -- No.-7-7493-to_do_cument review of the licensee's alternative to between-the-sea 1 s tes-ti ng ~ --
On-Ocfo-ber-Ti(J~- r99ff, -NRR-reqU-est-ed- - - --- ------- - ----
that the licensee furnish additional informatio Consumers Power submitted a Technical Specification change request -
on March 25, 1991, to modify Technical Specification 4.5.2, "Local Leak Detection Tests". The change expanded the Technical Specification wording to describe the requirements and acceptance criteria to which the licensee currently tests the personnel and emergency escape airlock A conference call was held with the licensee on May 28, 1991, to inform the licensee that their justification for not performing a pneumatic between-the-seal test in accordance with 10 CFR Part 50
Appendix J, was not acceptabl NRR has contacted the airlock vendor and found that the original door design specifications allowed for a pneumatic test. Additionally, neither NRR nor the vendor knew of a utility performing a seal contact check and seal 11fluff 11 in lieu of a pneumatic test. Additional information was discussed with the licensee regarding the revie The licensee requested withdrawal of the Technical Specification change request by letter dated July 29, 199 This essentially returned the licensee to a condition of questionable compliance to the previously cited requirement The inspector discussed this issue at the Management Intervie This is an unresolved item pending completion of the testin~ and/or maintenance activities required to perform the escape airlock between the seal test (Unresolved Item 91014-0l(DRP).
No violations, deviations or open items were identifie One unresolved item was identifie.
Operational Safety Verification (71707, 71710, 42700)
Routine facility operating activities were observed as conducted in the plant and from the main control roo The performance of reactor operators and senior reactor operators, shift engineers, and auxiliary equipment operators was observed and evaluate Included in the review were procedure use and adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems, and nuclear reactor protection systems~ Reviews of surveillance, equipment condition, and tagout logs were conducte Proper return to service of selected components was verifie Genera 1 The unit began the reporting period at essentially 100 percent power and was automatically removed from service as a result of two reactor trips (discussed in Paragraph 4, 11Reactor Trips 11 ).
In
____ addJtJ011, __ tll§_!J_n_H -~~s derated twice to approximately 60- percent powe The first was-bec-a-lise-of--bearfog--problems-with the -'~A!!_- ma-in-----:------ - ---
feedwater pump (discussed in Paragraph 5.c, 11Maintenance
) and the second was to perform preventative maintenance activities on the 118
main feedwater pum The unit completed the reporting period at essentially 100 percent powe Communications During this inspection period the inspector observed communications within the onsite organization and between the utility and the NR There were a number of strengths and weaknesse *
(1) Strengths Subsequent to the reactor trips (discussed in paragraph 4,
"Reactor Trips"), plant management was proactive in establishing communication with NRC personnel (both Region.III and NRR) to discuss the investigations performed to determine the cause of the trips and the corrective actions implemented and propose In addition, the licensee was able to discuss potential causes and why they were no longer considered to be problem (2)
Weaknesses (a)
(b)
(c)
(d)
Management expectations regarding the level-of-effort to be taken in troubleshooting the P-lA FW pump, following the July 12 reactor trip, were not clearly disseminated to the maintenance personnel. Therefore, it was unclear if initial troubleshooting efforts provided and documented the requisite information management sough The information was obtained later when the pump was again removed from service because of an unrelated proble Prior to the July. 12 trip, a calibration was being performed on a lube oil pressure gauge for the P-lA FW pum This gauge was dropped during installation which resulted.in an out-of-tolerance reading (low) of approximately 12 pound The technicians did not recognize the low reading and no one was informed that the gauge was droppe This gauge was subsequently used by an operator, resulting in the need to investigate apparent low lube oil pressure for the FW pump lube oil syste When the out-of-specification reading for lube oil pressure was found, the onshift crew was unaware that I&C had worked in the control cabinet the previous shift and that a calibration preventive maintenance activity was still outstandin During various conference calls with NRC concerning cable separation findings, information and data provided by the licensee was not always consistent. This caused the
_____ cohesiveness of the licensee's assertions to.become suspec-t ~-wfJ f di-rea -to--confusfan*and-delayed-understand-ing----- - - - -
between the licensee and NRC staf These were discussed with plant management before and during the exit intervie Service Water Temperature Warm lake water temperatures, during the month of May, prompted the licensee to review the maximum analyzed service water temperature and actions required should this value be exceede The FSAR analyses initially assumed a maximum service water temperature of 75 degree In about 1986, the analyses were repeated using
- a service water temperature of 80 degree In 1988, lake temperature briefly reached 80 or 81 degrees on a few occasion The licensee recently repeated the analysis using a service water temperature of 82 degrees and submitted the analysis to NRR for revie The highest recorded temperature for calendar year 1990 was 79 degrees. This topic was discussed during a licensee-initiated meeting, held in the NRC Region III, office on July 24, 199 The inspector reviewed the licensee's program and found that the gauge (TI-1319) used to verify service water temperature was last calibrated on June 17, 1990, and was not on a periodic calibration frequenc This was discussed with the licensee, who subsequently incorporated TI-1319 into their calibration progra Feedwater Transient On July 8, during a power escalation, the common controller for the main feedwater pumps was unable to maintain constant steam generator water leve The reactor was at approximately 58 percent power when the controller was placed in automatic. Steam generator water level strip charts subsequently recorded a number of level swings up to approximately 90 percent narrow-range leve The unit does not have an automatic turbine/reactor trip on high steam generator water level. The design does provide an auto-closure of the feedwater regulating valves at a steam generator water level of 85 percen Palisades Off Normal Procedure (ONP) 10, "Excessive Feedwater Increase," requires a manual turbine trip when water level exceeds 85 percent and is still increasing (Step 3.1). Strip chart recorders indicated that water level in both steam generators had exceeded 85 percent several time The inspector attempted to compare the strip charts for -feedwater flow and the position (open or closed) of the feedwater regulating valve In addition, the inspector interviewed the shift supervisor who was on shift during the transient and found that he was at the water level strip charts and was directing operation The interview determined that the crew was aware of the manual trip instruction of ONP 10, but that they also knew and verified that the regulating valves went shut at 85 percent leve The crew correctly analyzed that the water level increase above 85 percent was due to overshoot of the control system,
_______ not due __ to_c_Qn_1:i_!l_ujng flow of excessive feedwate The operators terminated the transfen_t_oy-ta-kfo!fmanual -contro-l of--the-feedwater-- ---- -- -------
regulating valve The inspector reviewed ONP 10 and it appeared that the operators did not comply with a literal interpretation of ONP 1 However, based on information contained in the "subsequent actions", the operators complied with the intent of ONP 1 In addition, the applicability of the procedure to this event was not perfectly clear *
- While the inspector was reviewing this transient, the operations superintendent performed a similar revie He initiated internal corrective action document D-PAL-91~111. The corrective action document contained a description of the event and an evaluation that the operator actions were correct. The corrective action document also required a review of the feedwater control system and a change to the water level manual trip setting stated in ONP 1 The change would permit the effect of the automatic closure feature to be seen before requiring a manual tri The inspector concluded that the licensee had performed a prompt evaluation of the cause of this event with appropriate management attention. _The corrective actions taken appeared adequate to prevent recurrenc Plant off-normal operating procedures should be written such that their applicability is clear; and, they should be followe In this instance, the operators apparently had only one procedure which addressed the situation they encountered, and they chose not to follow that procedure. Although the inspector concluded that the operators' actions did not adversely affect plant safety, he was concerned that this event might establish a precedent for operators to disregard procedural instructions based on other knowledg This item was discussed at the exit interview and with Region III managemen This is an unresolved item pending a discussion of this event between Region III and licensee management (Unresolved Item 255/91014-02(DRPJ)..72 Notifications On July 3, an unplanned reactor trip occurred from 100 percent power as a result of component failures in the reactor protective system that caused an indicated high primary coolant system pressure. See paragraph 4.a, "Reactor Trips" for a discussion of this even.
On July 12, an unplanned reactor trip occurred from 100 percent power as a result of a main feedwater pump trip that caused a low level in the 118 11 steam generator. See paragraph 4.b, "Reactor Trips" for a discussion of this even _________ 3 _____ Qn_JuJy_9_,.tb~_Jj~~see determined that some safety related circuits i nsta 11 ed d*u-rrng-ln-ifia rpl anr cons*tructfon*-were-- **- - -
apparently routed with the opposite safety related circuit *
This was the subject of a special inspection by a Region III DRS specialist, on July 15 and August In some instances, compensatory actions were required and were implemente In addition, this was the subject of numerous telephone calls between Region III, NRR and the License The incorrectly routed circuits did not place the plant in an unsafe condition, however, the licensee has determined that, in some cases, cable separation will be re-established during the next outag The
- result of the DRS special inspection will be documented in a subsequent inspection. Communication problems encountered during the conference calls were discussed in paragraph 3.b.(2)(d).
Safety System Walkdown
. The inspector verified operability of the Control Room Ventilation System by verifying system alignment using Palisades print M-218 sheet 6, surveillance procedure M0-33,
"Control Room Ventilation Emergf;!ncy Operation 11 and System Operating Procedure 24, 11 Ventilation and Air Condition System".
This walkdown included a verification that major flow path valves were in their correct positio No items were found that degraded the syste Tours During tours of the plant, the inspector observed what appeared to be a decline in the cleanliness standard for the turbine building and diesel generator room Two examples were the buildup of sand in the turbine building and dust "bunnies" in the diesel generator room These were discusse9 at the Management Intervie No violations, deviations, or open items were identifie One unresolved item was identifie.
Reactor Trips (93702) The unit tripped from approximately 100 percent power on July Subsequent trouble shooting by the licensee identified two failed trip relays -
11A 11 channel steam generator low pressure and 11A
channel primary coolant system (PCS) high pressure. Because of a common test bus, these failures resulted in an activation of the 110
channel PCS high pressure to cause a reactor trip from 2 out of 4 PCS high pressure. The failures were internal to the reactor protection system (RPS) and were not detectable by 11seal-in 11 trip annunciators or the plant computer because only input signals to the RPS are monitored by these two system The __ Ucens_ee __ \\'@S_ aj:>_le to reproduce the voltage changes across the relays associated wHffthe trip-:-Ttie-rerna-in-ing--trtp-re-lays-have---- - - --- --------
been checked; there were no additional failed relay The licensee reviewed the RPS and confirmed that this type of failure would not prevent a reactor tri The relay failures are apparently age relate The RPS was installed approximately 20 years ago and repair parts are no longer available from the vendo A limited number of spare relays are available to the license The licensee plans to replace the RPS during the next refueling outag Except for the problems discussed above, and some minor equipment problems that did not hinder or complicate plant recovery, the plant responded as designed during the reactor tri The reactor was made critical at 5:23 a.m. on July. The licensee kept Region III informed during conference calls on July 5 and In addition, the NRR project manager was on site July 5 and 6 and a Region III senior project engineer was on site July 7 and The inspector had no additional question However, this_
will be reviewed further when the associated LER is issue The unit tripped from approximately 100 percent power on July 12 b~cause of low water l~vel in the "B" Steam Generato The low water level occurred when the P-lA Feedwater (FW) pump tripped for unknown reason The plant responded as designe The plant remained in hot shutdown for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for troubleshooting and repair of miscellaneous item The unit was made critical at 11:23 a.m. on July 1 When the "N 1 FW pump tripped, the system engineer was investigating a FW pump low lube oil pres?ure proble During the investigation, the system engineer tapped the lube oil pressure gauge - tripping the FW pump immediatel While observing the FW pump control panel, the system engineer noted that the trip was electronic versus mechanica An individual must observe the control panel because most FW pump trip signals are not designed to "seal-in". Subsequent to the trip, the licensee latched the FW pump and reproduced the electronic trip by tapping the gaug Prior to returning the plant to service, the licensee attempted to trip the 118
F~ pump in the same manner ~ numerous attempts were unsuccessfu Based on this information the 1icensee returned the plant to service, initially using the 118 11 FW pump onl The licensee subsequently determined that the locally operated reset switch had been impregnated with lube oil. The lube oil contained enough contaminants to cause the switch to short, tripping the FW pum During preventative maintenance activities on the 118 11 FW pump the licensee found that the trip switch was also degrade Since January 1990, the plant has tripped (including this trip) four time Three-of these_p_la_at ___ tr.iR~ _were preceded by FW flow transients caused by a trip* of a FW pum The--cause-cff the-*previo-i:rs-pump-tri-ps-wa-s- -- - ----- -- -- ---
never determined and may never be determir1e However, the local reset switches appear the likely caus No violations, deviations, unresolved or open items were identifie.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repairs) and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl.
The focus of the inspection was to ensure the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with Technical Specifications. The following items were considered during this review: the Limiting Conditions for Opefation 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: Work Order (WO) 24102627, "Containment Spray Pump P-54C Breaker Inspection.
The inspector observed portions of the inspection performed per WO 2410262 Both the workmen involved and the system engineer demonstrated ar. excellent working knowledge of the breake WO 24103310, 11 K-7A, Megger Checks.
11 WO 24103312, 11 K-7A, Investigate Noise Inside Governor.
On July 19, the unit was derated to approximately 60 percent power and the P-lA FW pump was removed from service for further troubleshooting. During the course of this troubleshooting, the turning gear housing for K-7A (the pump turbine-driver) was removed to determine the source of mechanical noise emanating from within the housin Investigation showed the layshaft bearing's bore and thrust face to be severely worn with a cracked bearing cap and a loose drive gear nu The licensee performed the requisite repairs and returned the P-lA FW pump to service on July 2 No violations, deviations, unresolved or open items were identifie Surveillance (61726, 42700)
The inspector reviewed Technical Specifications required surveillance testing as described below and verified that testing was performed in accordance with adequate procedures. Additionally, test instrumentation was calibrated, Limiting Conditions for Operation were met, removal and
__ r_estor_at_ion Q_f _ th_g _affected components were properly accomplished, and
'
test results conformeC!-wrtfi Ted1nicar-Sj:fecif;-cati-ons-and--procedure-- - ---- --'-- ----- ----:
requirement 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 inspecte M0-33 Control Room Ventilation Emergency Operatio * Q0-11 MR-9 GOP 12 The inspector performed a detailed review of this procedure using drawing M-218 (sheets 6 & 7), FSAR section 9.8, Standard Ord.er 54 and the applicable Technical Specificatio The inspector questioned the need for 1000 CFM outside makeup air during the emergency mode of operation. Since this makeup rate was established, improvements have been made to the integrity of the control room envelop A control room over pressurization of twice the minimum required by the Technical Specification is achieved using 1000 CFM makeup air. The plant analysis for makeup air flow of 1000 CFM shows this will not result in an over exposure to Contro 1 room personn.e However, reducing the amount of makeup air would also reduce the potential exposure to control room personne This was discussed with the system engineer, who acknowledged the comment and stated that the Design Bases reconstitution program had previously documented this concer The system engineer implemented measures to reduce makeup air and still keep an acceptable margin above the Technical Specification minimu Quarterly Containment Isolation Check Valve Testin During this test, a check valve failed to seat as indicated by excessive leakag The crew implemented the corrective actions of the surveillance procedure by deactivating the automatic isolation valv In addition, the operators varied the test boundary valves to confirm that the leakage was through the check valve and not through the deactivated isolation valve. This was not a requirement of the test, however, it was a good course of action by the crew to confirm containment integrit Emergency Plan Radiation Detection Instrument Checklis Primary instrument Calibration
- -----T~~e *-:rnspecfcfr--observed-th-aC'lilith-of-the**c*ontro*-i---room* ------------------------ ---
operators were knowledgeable of plant status while each channel was being bypassed and restore No violations, deviations, unresolved or open items were identifie.
NRC Bulletins and Generic Letters (92703)
The inspector reviewed the NRC communications listed below and verified that: the licensee had received the correspondence; the correspondence was reviewed by appropriate management representatives; a written response was submitted if required; and, plant-specific actions were taken as described in the licensee's respons (Closed) NRC Bulletin 89-03, "Potential Loss Of Required Shutdown Margin During Refueling Operations." This bulletin was previously discussed in Inspection Reports 255/89031 and 255/9001 The NRC has reviewed the licensee response (dated February 1, 1990) and determined that the response was satisfactory. * The NRC requested confirmation from Consumers Power Company when the training and procedure updates were complete The training and procedure revisions were completed on October 5, 1990, as documented on Action Item Record (A-NL-90-18), however, this information was not formally provided to NR Internal correspondence DHD 91-034 documents the need to formally provide this information to NR (Closed) Generic Letter 88-14, "Instrument Air Supply Problems Affecting Safety Related Equipment."
The NRC review is documented by NRC TAC Number 71693, which was closed by letter dated June 13, 199 No violations, deviations, unresolved or open items were identifie.
Unresolved Items Unresolved items are matters abo~t which more information is required* in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items identified during the inspection are discussed in Paragraphs 2.f. and.
Management Interview The inspectors met with licensee representatives ~ denoted in Paragraph 1
- on August 14, 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 discusse The licensee did not identify any such documents/processes as proprietar Highlights of the exit interview are discussed below: Strengths noted:
(1)
(2)
Post trip communications with the NRC (Paragraph 3.b.(1),
"Operations").
Discussions with the NRC pertaining to service water temperature (Paragraph 3.c). Weaknesses noted:
(1)
(2)
Communications within plant organizations and to the NRC (Paragraph 3.b.(2)).
Cleanliness standards in certain parts of the plant declined (Paragraph 3.g).
l Unresolved Items (1)
The unresolved item pertaining.to between-the-seal testing of the escape air lock was discusse The licensee was informed that DRS personnel are expected to look at thi~ item during the next ILRT inspectio (2)
The unresolved item pertaining to the feedwater transient was discussed, including general discussion of clarity in determing procedure applicability (Paragraph 3.d). Reactor Trips The two reactor trips were discussed, with. the conclusion that the trips were uncomplicated, in that plant systems and operators performed properly in respons