IR 05000255/1992006

Insp Rept 50-255/92-06 on 920128-0309.No Violations Noted. Major Areas Inspected:Plant Operations,Maint,Surveillance, Radiological Controls,Security,Outages,Procedure Review, Safety Evaluations & Plant Review Committee

ML18058A311
Person / Time
Site:	Palisades
Issue date:	03/20/1992
From:	Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18058A310	List: IR 05000255/1992006 ML18058A309
References
50-255-92-06, 50-255-92-6, NUDOCS 9203310116
Download: ML18058A311 (21)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION III*

Report No. 50-255/92006(0RP)

Docket No. 50-255 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 License No. DPR-20 Fa.tility Name:

Palisades Nuclear Generating Plant Inspection At:

Palisades Site, Covert, MI Inspection Conducted:

January 28 through March 9, 1992 Inspectors:

Approved By:

J. * K. Heller B *. E. Hal ian D. G; Passehl Inspection Summary J. R. Roton C. E. Brown R. l. Bywater 2A DATt I

Inspection from January 28 through March 9, 1992 *(Report No. 50-

. 255/92006CDRPl)

Areas Inspected:

Routine unannounced inspection by the resident~inspectors of plant operations, maintenance, sur~eillance, radiological controls, security, outages, procedure review, safety evaluations, plant review committee, and plans for coping with a strik No Safety Issues Management System (SIMS)

items were reviewe Results: No ~iolations or deviations were identified in the areas inspecte The strengths, weaknesses, one Open Item, and an Unresolved Item are discussed in paragraph 12, "Management Interview."

9203310116 920320 PDR ADOCK 05000255 G

PDR

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• ' *

DETAILS Persons Contacted

• Consumers Power Company

• G. B. Slade, Plant General Manager

• R. M. Rice, Plant Operations Manager

• R. D. Orosz, Nuclear Engineering & Mainteriance Manager

• P. M. Donnelly, Safety & Licensing Director

• K. M. Haas, Radiological Services Manager

• J. L. Hanson, Operations Supe~intendent

• R. B. Kasper, Maintenance Superintendent

• K. E. Osborne, System Engineering Superintendent D. D. Hice, Chemistry Superintendent - * *

L. J. Kenaga, Health Physics Superintendent C. S. Kozup, Technical Engineer

.

.

• T. J. Palmisano, Administrative & Planning Manager Nuclear Regulatory Commission <NRC)

-*J. K. Heller, Senior Resident Inspector

• J. R. Roton, Resident Inspector

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..

• Denotes some 6f those present at.the Management Interview on March 17, 199 *

Other members of the plant staff, and several members 6f the contract security force, were also contacted during the inspection perio.

Operational Safety Verification (71707, 71710, 42700, TI 2515/113)

Routine facility operating activities were observed as conducted in the plant and from the main control roo Steady power operation, plant shutdown, refueling operations and system(s) lineup and operation were observed as applicabl *

The performance of reactor operators and senior r~actor operators, shif 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 activities. Evaluation, corrective action, and response for off normal' conditions were examine This included compliance to any reporting requirement General

-

The unit began the reporting period at essentially full powe On February 5, 1992, the licensee started a power reduction in response to inoperable Main Steam Isolation Valve (MSIV) control

circuits. The power reduction was stopped and power returned to essentially full power when a Temporary Waiver of Compliance (documented in paragraph 2.b. "Temporary Waiver of Compliance")

• was approved by the NR The unit was removed from servke on

. February.6, I992, for a refueling and mai*ntenance outage when the

• licensee determined an on-line repair was not practicabl The unit was in a refueling and*maintenance outage at the end of the r~porting perio * Temporary Waiver of Compliance On February 5, I992, the licensee verbally requested a Temporary Waiver of Compliance {TWOC) from the shutdown requirements of.

Technical Specifications 3.5.3. The TWOC was requested because reviews conducted by the licensee's configuratiOn control group determined that the control circuity for the Main Steam Isolation Valves {MSIVs) had inadequate isolation between class IE and non-class IE circuit **

There is one MSIV installed on each main steam header. *The MSIVs are check valves held open by a pneumatic cylinder. Both MSIVs close on ~ low pressure signal from either steam generator or a containment high pressure signal. The air supply for each MSIV is controlled by three pairs of solenoid operated air supply and vent valve One set is located in the turbine building and two sets are located i'n the auxiliary building. Closure of any air supply valve and opening of any vent valve will clbse the associated*

MSIV~

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The licensee determined that the control valves located in the auxiliary building were not qualified to survive a harsh environment subsequent to a main steam line break outside the containmen If the control valves located in the auxiliary building failed, the power supplies - which are common to the power supplies for the control valves located in the turbine building - could fail and preclude operation of the valves located in the turbine.building. Based on this, the MSIVs were declared inoperable and the licensee entered a Technical Specification action statement that required the plant to be in hot standby in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; hot shutdown in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown in the following 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The,licensee evaluated the problem and verbally requested a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TWOC to permit continued evaluation and implementation of a *

r~pair. The NRC:{Region III and NRR) verbally granted the TWOC at 6:49 p.m. on February The licensee provided a written request within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following ve,rbal authorizatio *

A provision of the TWOC required placement of a knowledgeable individual at the local panel for the turbine building control valves, to manually close the MSIVs if these valves did not automatically close when require The inspectors verified that a

C*.

knowledgeable individual, who was in constant communication with the control room, was stationed at.the control pane.

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The inspectors also determined through interviews, review of logs and review of status boards, that the information contained in the TWOC was di ss_emi nated to the operating crews.. The inspector found

• that the MSIVs were declared inoperable on the shift supervisor status board. * The status board al so* stated that a TWOC was in effect for the next 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> *

Another provision of the TWOC fequired compliance with the action statement of Technical Specification 3.5.3 at any time it was determined that a repair was not practical. The licensee determined that a repair would require a power supply modification and a hardware modification to assure the control and logic

circuits in the turbine building were redundant to the control and logic circuits in the auxiliary building. Another option was to move the control valves out of the auxiliary building.. Based on this-the licensee terminated the TWOC at 6:30 p.m. on February 6 and re-entered the shut down requirements of Technical

Specification 3. The written TWOC request was reviewed by Region III on February 6 and determined to be a quality submittal. A few minor enhancements were identified and discus~ed with the license Most notable was the need to discuss 10 CFR 51. 22 as th-e TWOC applies to exclusion from environmental revie There appeared to be two ~auses for the control circuity proble The first was a desi~n change implemented in the early 1970s to install a second control circuit in the turbine building. This

• change did not duplicate the logic or power scheme in the turbine buildin The second was a failure to assure that control circuity required to operate during and after an accident was qualifi~d for the potentially harsh environmen These items were the subject of a special inspection documented in Inspection Report 255/920ll(DRS).

.

Auxiliary Feedwater Pump Room During a tour of the auxiliary feedwater pump room, the inspector noted that concrete was spalling from the north-west corner and ceiling. The inspector discussed this problem with system engineering and was informed that repairs would be implemented this outag The inspector's interest was in the* root cause evaluation~ During feedwater heater replacement activities performed during a previous outage, a feedwater heater was moved.

over this are In addition, a feedwater heater pedestal located in the general area required corrective action because it was settling. It was unclear if these activities were related or if other.factors might be affecting the structural integrity of the auxiliary feedwater pump roo The licensee evaluation continued.

• This is an open item pending completiori of the licensee evaluatio {Open Item 255/92006-0l{DRP)).

Plant Maneuvering The inspector reviewed plant activitie.$ as they a-pplied to*the following activitie {l)

Power reduction, plant shutdown and plant cooldown per General Operating Procedure {GOP) 8 and {2)

Shutdown cooling operations per GOP 1 {3)

Draining the Primary Coolant System {PCS) per step 7.1.6 of System Operating Procedure (SOP) Reduced Inventory Operations The licensee started draining the primary.coolant system (PCS) at the same time another power plant lost shutdown cooling during PCS*

draining.activities. As a result of that event, the inspector reviewed the licensee activities during the draindow {l)

The licensee had removed the pressurizer.manway cover to

~stablish a vent path~

(2)

At least two independent level indicators were operable with the readings in agreemen The tygon-tube level indicator was functional, with an operator stationed at the jndicator

. and in telephone c.ommunication with the.control roo (3)

The level increase and draining of the primary system drain tank matched the drain rate from. the PC ( 4)

The PCS drain was stopped every hour to assure that a vacuu*m was not being drawn on the PCS and that the level i~dicators matche (5)

The equipment hatch was shut and refueling containment integrity establishe *

(6)

The drain rate was controlled by gravity and not accelerated by use of a cover ga Evolutions involving PCS inventory reduction were conducted in a deliberate and meticulous fashio Licensee management was extremely sensitive to *issues involving reduced inventory operation The inspector monitored a session of the licensee's shutdown risk training class. The class was well structured and thoroug It is to be given to a broad spectrum of plant

• personne Indepth intervi~ws with a vertical sl~c~ of licensee

• personnel revealed an excellent knowledge of both shutdown risks and the windows work scheduling method as well as the particular risks involved with reduced inventory operation Additionally, the inspector obtained information, per the requirements of TI 2515/113, on licen~ee practices for maintaining reliable decay heat removal during outages and has no further commen This information was provided.to NR * FHS0-9 Movement of Fuel Pool Divider Gate During the removal* of the fuel pool divider* gate, the gate pins bound against the bottom of the gate hooks while the lift continued. This ~esulted in a broken sling and a dropped fuel pool divider gate.. This*was the subject of an internal correctiv action documen The rigging configuration was a two point lift directly attached to the spent fuel pool auxiliary crane. The inspector discussed potential corrective.actions with the corrective action evaluator.. The.Preliminary corrective action did not address the potential loading on the spent fuel pool auxiliary crane. The crane is rated at 15 tons. The procedure specified a minimum sling rating of 2 tons..If higher rated slings were used and the slings had a standard safety factor of 5 to 1, the potential exists that the rating of the crane was exceeded. This was discussed at the management intervie The inspector reviewed the rigging requirements specified in Attachment 1 of FHS0-9 and recalculated the minimum rating requirements of the slings. The specified ratings were

• appropriate to lift the gate using the minimum specified sling length. The inspector noted that the rig~ing configuration did not require the use of a load cell or chain fall to assure that there was no unexpected binding when the initial lifted force w*as applied. This was discussed at the management intervie Safety System Walkdown The inspector verified the operability of the shutdo~n cooling system by verifying alignment using Palisades 11 Low Pressure Safety lnje~tion System" {LPSI) check list and piping and instrumentation diagram M-204, Sheets Al, 1, IA, and I This walkdown included a verification that major flow path valves were in the correct position. During the walkdown, hanger EC1-H42 was found in a degraded condition. The inspe~tor notified the system engineer who inspected the hanger and documented its condition on an internal corrective action document. The ~~aluation determi~ed the LPSI was operable without the hanger installed. *The hanger was restored prior to entering shutdown cooling condition No other items were found that degraded the syste No violation~, deviations, unresolved or open items were identified.

• • *

Maintenance (62703, 42700)

Maintenance activities in the plant were routinely inspected, including both corrective maintenance {repairs) and preventive maintenance~

Mechanical, electrical, and instrument and control group maintenance

• ctivities were included as available. *

The focus of the inspection was to assure 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 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 work ~rder (WO) activities were inspectedi WO 24103287, "Heater Drain Pump P-lOA Suction Leaks By, Inspect and Repair."

WO 24105193, "Heater Drain Pump P-lOA Discharge Check ~alve, Disassemble, Inspect and Repair."

WO 24102071, "Emerg~n~y Diesel Generator 1-1, Replace Air Line Per SC-91-107."

WO 24102392, "High Pressure Turbine, Disassemble Uppe~ Half HP Components."

WO 24104107, "High Pressure Turbine, Disassemble HP Pedestal and Rotor.

WO 24102407, "High Pressure Turbine, Clean and Insp~ct HP Upper Components."

WO 24102410, "High Pressure Turbine East Cross-Under, I~spect and Repair Pipe."

WO 24102411, "High Pressure Turbine West Cross-Under,_ Inspect and Repair Pipe."

WO 24102396, 24102398, 24102400, and 24102399; "Moisture Separator and Reheater Inspection."

WO 24001183, "Electro Hydro/Gov Control Cabinet DEH Modificatio Installation and Checkout. (FC-844)."

WO 24103917, "Station Power Transformer 1-1, Region Repair and Testing."

• WO 36100120, "Install Nozzle Dams Steam Generator "A" and "B"."

WO 24200633, Events Recorder ER,... Repair Taped Splices on Wires."

WO 24104323, "Remove Recorder on Feedwater Pump P-lA t~ Closeout TM-91""'.058."

WO 62260340, "Main Feedwater Controls Upgrade, Remove Instruments, Hardware,.Wire, *Terminations in C-01 Panel."

WO 40250540, "Auxiliary Feedwater Controls Upgrade: Modify Internal Wiring Control ~oom C-01."

• WO 24105720, "Alternate Steam Supply to P-88 From Steam Generato Valve Sticking Closed." WO 24100842, "Heater Drain Pump Reb~ild." {Observed Removal)~ * WO 24104672, "Feedwater Pump~ Miscellaneous Mechanital System Work." WO 24101811,. "Heater E-3A Drain Valve {CV-0613} Stickin Rebuild."

• * WO 24105436,

"H~ater E-38 Level Control Valve {CV-0623}

Disassemble, Inspect and Repair Valve and Actuator."

For several of the WOs listed ~bove, the inspector noted that the

• mechanics or technicians involved in the repair or maintenance activity demonstrated a thorough understanding of the procedur The procedures were clear and concise as to the work to be performe Tools and other documentation required to complete the task appeared-to be staged at the job site indicating a detailed pre-job review of the work order was performed prior to starting the tas 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 i accordance with adequate procedures. Additionally, test instrumentation was calibrated, Limiting Conditfons for Operation were met, removal and restoration of the affected components were properly accomplished, and test result~ conformed with Technical Specification~ 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 inspected: Rl-59, "Calibration of PCS Over-pressure Protection." Q0-14,' "Inservice Test Procedure: Service Water Pumps." {Partial for P-7B) Rl-67, "Functional Test of Fire Detection System, Inside Containment." M0-26, "Fire Suppression System Valve Alignment and Fire Hose Station." RI-86E, "Refueling Isolation Monitor Calibration.~

r Q0-15, "lnservice Test Procedure: Component Cooling Water Pumps."

{Partial for P-52C).

. Q0-13, "Iodine Removal Valve Stroke." M0-7C, "Fuel Oil Transfer Pump." {Partial for P-18A) RM-24, "Main Steam* Safety Valve Setpoint Test." Sl-7, "Functional Safety Test of Fire Detection System Outside Containment."

RT-88, "Shutdown Cooling/ESS Pump Suction Line Te~t." {Partial Test for Containment Sump Lines to CV-3029 and CV-3030). QE-9, "Diesel Fire Pump Battery Surveillance." RI-77, "Pressure Relief Valve Monitoring System Calibration." RE-83A, "Service Test - Battery No. DOI." RE-83B, "Service Test - Battery No. D02. "'

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

Radiological Controls {71707) On February 6, the licensee shipped a spent fuel storage rack to a contractor for compactio The rack had been removed from the spent fuel pool approximately ten years ag When the truck stopped enroute, it was discovered that the shipping container was leaking wate Response groups from the Palisades plant, Cook plant, and local emergency teams responde After surveys indicated that the water was not contaminated the shipment was returned to the site. This was the subject of a special NRC inspection documented in Inspection Report 255/92008{DRSS).

• The inspector observed activities at the spent fuel* pool and the exit area for the containmen The undressing area for the containment consisted of a double step off pad to minimize the spread of contamination. The first pad required removal of the potentially contaminated outer clothing prior to entering the general Ondressing area. The work area for fuel reconstitution was in the general undressing area. *Fuel reconstitution required

• . occasional removal of tools from the spent fuel pool. These activities were done using good radiological work practice However the workers did not remove the potentially contaminated outer clothing while moving in the general undressing area. This potential compromise of conta~ination control for the general undressing area was discussed with the health physics (HP)

superintenden The inspector observed activities at the auxiliary building actess control poin One observation pertained to the duty HP techntcian's review of a contractor's reason for entry into the auxiliary building. The contractor stated he wanted to determine if a ladder or scaffolding was required to facilitate valv maintenanc Initially the contractor stated that he was not sure where the valve was located. Prior to permitting entry the HP technician required some assurance that the contractor knew the*

• general location of the valve. A map was then found in the work order packag The inquiring nature of the technician assured that proper clothing was worn, andthat the contractor's time in the area and po~sible dose were minimize No violations, deviations, unresolved or open items were identifie.

Security (71707)

Routine facility security measures, including control of aciess for vehicles, packages and personnel, were observe Performance of dedicated physical security equipment was verified during.inspections in various plant areas. The activities of the professional security force in maintaining facility security protection were occasionally examined or reviewed, and interviews were occasionally conducted with security force member *

During this inspection period a fitness-for-duty and an access control problem occurre The information was provide to Region III security and fitness-for-duty specialists. Any additional qu~stions will be addressed by separate correspondenc No violation~, deviations, unresolved or open items were identifie.

Outages (37700, 42700, 60705, 60710, 61701, 61715, 86700) General The refueling outage *was ~tarted 17 days ahead of schedule when it

was determined that repairs to the control circuity for Main Steam Isolation Valves could not be completed within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period granted by the Temporary Waiver of Compliance discussed in paragraph 2.b of this report. The following milestones have been achieved:

Major Outage Milestones Open Generator Breakers PCS in Hot Shutdown PCS in Cold Shutdown S/G Nozzle Dams Installed S/G Commence Eddy Current Testing Reactor Pressure Vessel Head Removed Upper Guide Structure Removed Commence Fuel Shuffle Date Completed 02/06/92 02/07/92 02/09/92 02/26/92 02/29/92 02/27/92 03/03/92 03/07/92 Of the 1817 Work Orders (WO) scheduied to be completed during the outage, approximately 757 have been complete Of the remaining 1060 WOs, 751 are in progress and 309 remain in the planning phas Although not fully prepared to commence the outage early, the licensee did an outstanding job of adjusting its schedule to minimize the effect of the early start. Specific strengths were noted in the performance of the Outage Manager, the Operations Department Planning Coordinator and the Shift Managers.. These people have been instrumental in ensuring work was performed only-when requisite plant conditions were establishe In addition, these individuals have maintained the global overview required to ensure the safety of the plant and personnel involved in the various repair and maintenance activitie Fuel Assembly Attached to Bottom of Upper Guide Structure CUGSl On February 29, 1992, licensee personnel observed that a fuel assembly remained firmly attached to the bottom of the UGS as the UGS was being lifted from the reactor vesse The plant had been shut down since February 7 for a refueling and maintenance outag The stuck fuel assembly was from the p*eriphery of the reactor cor During two previous operating cycles this fuel assembly had also been located in this positio The area above the reactor had been flooded to the refueling level which provided adequate radiation shieldin The licensee declared an Unusual Event at 11:05 p.m. on February 2 Refueling containment integrity was established by closing the equipment hatch. After the initial 10 CFR 50.72 notification, three conference calls were conducted between the licensee and various members of the NRC (both Region III and NRR).

In addition, telephone communications were maintained between

• .Region III and the-licensee whenever recovery activities were conducte A fourth conference call to brief commissioner assistants was conducted by Region III.

The bottom of the fuel assembly was about four and one-half feet above the top of the reactor cor By 4:40 p.m. on March 1, a series of cables had been installed to form a web which would restrain the fuel bundle if it di~lodged from *the UG Evaluation of the worst case scenario by the licensee determined that if the bundle fell, offsite impact would be mino On March 1, the licensee prepared to free the fuel assembl Palisades Nuclear Plant Fu.el Handling Procedure 16 (FHS0-16) was written to recover the fuel assembly.. The procedure consisted of two main phase The first was removal. of the fuel assembly from the ~GS and stabilization of the assembly in the vertical

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position. The second was grappling the fuel assembly with the

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spent fuel pool auxiliary hoist handling tool and movement to the tilt pit transfer machine. FSH0-16 was approved, training was conducted and spedal recovery tools were fabricated and teste On March 2, the li~e~see lowered a grappling device through the UGS and connected it to th~ top of the fuel assembl Additionally, a hydraulic "horseshoe... was attached to the fuel assembly and the series of restraining cables removed~ The horseshoe was held in place by three cables attached in the south, east and west directions. Additionally, a containment entry was made by Westinghouse to prepare.the laydownarea for the UGS and erigage a setond grapple ("J-hook") to the top of the fuel assembl I~stallation of the "J-hook" was not successful.

Following redesign and testing, a second grapple was successfully attached to the top of the fuel assembly~ When tension was placed on the second grappling device the fuel assembly detached from the UG The licensee attempted to lower the assembly in this configuration; however, the original grapplirig device was too large in diameter to pass through the UGS flow hol The licensee detached the original grappling device and lowered the fuel assembly with only the second grappling device attathed and the*

hydraulic "horseshoe" to control the descent. This activity was completed leaving the fuel assembly resting on the core and leaning against the side of the core barrel. The second grapple*

was ~em6ved to facilitate removal of the UG The. horseshoe provided assurance that the fuel

~ssemble would not fal On March 3, the UGS was remove At 12~30 p.m., on March 3~ the final prej6b briefing was conducte for the lifting and transport of the fuel assembly to the tilt machin At 4:18 p.m., the fuel assembly was placed in the "west" side of the tilt machine and the licensee exited the Unusual Even A similar event occurred during the 1988. refueling outag The fuel assembly was different but located in the same core positio One difference between this event and the previous event was the use of the second grappling device. In the previous event the

fuel assembly was freed after applying force from a removal too In this case, the bundle was freed after the second grapple was installe Initial inspection of the fuel assembly consisted of a visual inspection of the fuel bundle and a dimensional check of the top of the fuel bundle; no problems were identified. The 1-icensee'.s corrective actions will continue with inspection of the UGS scheduled to begin after the fuel moves are complete This event will be the subject of an LER and will be further reviewed during closeout of the LE Steam Generator Nozzle Dam Installation On February 26, while installing nozzle dams in the hot leg of the*

"A" steam generator the licensee discovered that one of the eight pins used to hold the "dry" nozzle dam in position would not*

engage and lock-in. This particular pin was located in the number seven positio When hydrostatically tested, the "dry" noizle dam failed the between-the-seals hydrostatic test *(the seals themselves had passed their* hydrostatic test). Based on previous experience with leaking nozzle dams, the license proceeded with flood-up of the cavity to support refueling operation The inspector questioned why a test fit of the nozzle dams during the steam generator replacement outage did not identify the fit-up proble The inspector was informed that the dams were not test fit as part of the steam generator replacement project because of scheduling problem It was additionally reported to the inspector that the same pin in the "dry" dam of the "B" steam generator hot leg would not fully engage and lock. Apparently the template used to machine/drill the holes for the "dry" dams was not properly bench marke Zebra Mussels During this outage, the licensee performed an underwater inspection of the firewater and service water intake ba This inspection revealed a significant number of zebra mussels firmly attached to the sides of the ba The ambient water temperature was and remained below the zebra mussel dormancy temperatur During th*e previous summer, the 1 i censee had treated the bay with Betz ClamTrol and chlorine in an attempt to prevent mussel growt During this outage, the component cooling water heat exchangers, diesel generator heat exchangers, cooling towers, condensor and containment air coolers were inspected. A few dead mussels were found in the component cooling water heat exchangers and in the cooling towers; none were found in the other areas. These results indicated that the program prevented blockage caused by rampant growth and controlled the ~rowth in the treated ar~a. However, the number of mussels in the intake bay indicated a need to redefine the injection points for the Betz ClamTro This was

• discussed with the system.engineer who stated that the injectio point was being reanalyze The dormant mussels are being mechanically removed from the suction ba The inspector expressed a concern in a previous inspection report that zebra mussels may have infected the firewater system and possibly the cross-connection to the Auxiliary Feedwater Pump Recently, the Zion Nuclear Power Plant reported a buildup of sand and zebra mussels in the emergency makeup line to the Auxiliary Feedwater Pump This information was shared with the license Procedure Review The inspector reviewed the working and control copies of RVG-M-2

"Removal of Reactor Vessel Head" and RVI-M-1 "Removal of the Upper Guide Structure (UGS),

11 and made the following observations:

(1)

(2)

(3)

. RVG-M-2 at Table I specified the sequence for stud detensioning using three stud tensioners. The sequence specified that the tensioners be placed on the 18th stu Step 8 contained an obvious typographical error by stating the wrong stud in the sequence. A pen and. ink change was made and the evolution continue The editorial chinge was not approved by a member.of the plant staff nor was a

• document issued to assure that the editorial change be made permanen RVG-M-2 at step 3.7.~ and RVI-M-1 at step 3.2.2 required use of a calibrated load cell and required that the calibration due date, calibration date and serial number be documented in the procedure. These steps were marked 11N/A 11 with no explanation or signatures provide The inspector interviewed the contractor manager who indicated that the installed load cell for the polar crane was use The inspector reviewed the plant records and found that the installed load cell was not included in the plant calibration progra RVG-M-2 at step 5.9.15 specified a maximum head removal weight of 135 ton The procedure also specified that if this weight is exceeded the lift shall be stopped and evaluated for interferenc The recorded weight was 159 tons which exceeded the maximum weight by 24 ton The inspector interviewed the contractor supervisor responsible for the head lift and found that the evaluation was performed on the spot by visually observing that only the head was being removed. This evaluation was not documented or discussed with any member of the plant staff. The inspector noted that the procedure required an evaluation and did not grant permission to continue once the evaluation

. was performe In addition, it was unclear how an

• evaluation can be performed since the weight was exceeded prior to movement of the head above the seating surfac The recorded weight exceeded the containment polar crane rating of 135 tons by 24 tons. The inspector also questioned why a crane operator continued with a lift that exceeded the crane ratin When this item was identified to the licensee the crane manufacturer was contacte He performed a visual and dimensional check of the critical points of the crane and documented that the crane was-acceptable for continued use and had not been damaged due to a 159 ton 1 i f (4)

RVI-M-1 specified a maximum lift weight of 34.5 tons and required an evaluation if that weight was exceede The recorded weight was 38 ton As in the head removal procedure, the evaluation was performed on the spot by the contractor, was not documented, reviewed, or approved by a plant employee, and the procedure did not permit.the operation to continue with the weight exceede In this case a Senior Reactor Operator (SRO) for refueling operations was in the area to observe the UGS_removal and to verify that a fuel bundle did not remain attached to the bottom of the UG The inspector interviewed the SRO, who indicated that he was not consulted when the maximum weights were reached and exceede The licensee had previously identified this ftem and documented the problem on an*

internal correction documen The inspector has reviewed each item listed abov Collectively they indicate a procedure compliance problem or a contractor oversight proble These are considered an unresolved item pending additional review by the inspector to determine -if enforcement action is appropriat (Unresolved Item 255/9200.6-02(DRP)). Technical Procedure Review (46500) RVG-M-5

"Reactor ~ead Installation."

The inspector performed a technical review of RVG-M-5 u~ing vendor manual M-I-B SH-929~ "Reactor Vessel Assembly" as a referenc The inspector found that the technical instructions of the vendor manual were incorporated into the procedur The inspector also found a provision at several procedure steps that permitted a supervisor to waive Q.C. notification points i Q.C. was not availabl The Q.C. hold points did not contain a similar provision. This procedure and others with similar provisions are used by contractors. This means that a contractor who may have contractual requirements to meet or exceed a schedule has permission to waive a Q.C. notification without any oversight

• *by plant personne The inspector has not identified a problem; however, the inspector has noted'that problems may occur if a new contractor with no previous work history at Palisades uses the procedures. This was dis~ussed at the exit intervie *

RVI-M-1

• "Removal and Storage 9f the Upper Guide Structure (UGS)"

.

The inspector attempted to perform a technical review of the procedure using vendor file M-I-B-E(2), "Internal-Upper Guide.

Structure" as a reference. This file did not contain a written instruction; therefore, th.e technical review was limite The inspector could not find a procedural requirement to verify that the UGS removal rig ~as leveled with respect to the UGS

.

seating surfac _The UGS is a three leg lift~ each leg with a leveling device~ A review of the UGS work order history file identified one attempt (WO 24905884) to level the UG This was aborted becau~e the leveling nuts were strippe The inspector interviewed personnel involved with this evolutio Some indicated that leveling was attempted with th~ refueling deck as.~

reference~ The nuts were repl~ced (WO 24005555), however, no attempt was made to level the UG _The inspector identified that it may be more appropriate to level the UGS removal rig with respect to the seating surface of the UGS instead of the refueling dec Level*ness of the UGS removal fixture may have contributed to the stuck fuel assembly discussed*

in paragraph 7.b, "Fuel Assembly Attached to Bottom of Upper Guide

• Structure (UGS)."

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

Safety Evaluations {42700)

The inspector performed a review of Palisades Nuclear Plant Administrative Procedure No. 3.07, "Safety Evaluations~" This review was conducted to assess plant control of the 10 CFR 50.59 safety evaluation process. The following observations were identified and discussed with the license The procedure was well detailed and provided clear directions on performing the safety evaluation checklists. Definitions were extensive and informativ The procedure referenced the plant capability to perform full text computer searches of the FSAR, the Technical Specifications, the Standing Orders, and Safety Evaluation Reports. This method was considered a useful tool in ensuring that subtle changes to the facility were not overlooked by missing an FSAR reference to a component or system.. The procedure stated that if the computer search method was employed, the search phrases should be listed on the SE checklist. The inspector noted that either the computer search was not being used

• I *

. or the procedure requirement to document the search method used was* not implemented, since a review of approximately 25 safety evaluations did not reveal any use of the computer search metho Listing the search phrases could assist management review of the comprehensiveness of the safety evaluation. *The inspector discussed this aspect with the appropriate superviso Section 5.2.5.d-of the procedure required that any "direct or indirect conflict with TS" be identified as an item which tan not be changed per 10 CFR 50.59. The procedure lists two excellent examples of indirect TS conflicts which should be conservatively flagged as requiri~g a TS chang One example was replacement of an instrument with another model which cannot be surveillance tested in the manner stated in T The inspector questioned if this guidance was used when determining if the reactor protection system modification could be performed under 10 CFR 50.5 The modification replaced a flow selector setpoint switch and initially did not identify the need to request a TS chang The issue was discussed with the unit supervisor and resolve Section 5.4.2.c of the procedure stated that one condition requiring an FSAR update was safety evaluations which justify alternative means of satisfying licensing bases when those means conflict with existing TS or FSAR description The inspector pointed riut that a safety evaluation cannot conflict with an

existing T A TS change must be requested first. * The uni supervisor committed to change the procedure, stating that the reference to TS should be "TS basis".

-

The safety evaluation procedure required that an Unreviewed Safety Questi~n {USQ} determination be made on a package that has already been mark~d for a TS ch~nge. The inspector questioned the logic of this process, since the determination of no significant hazards

{covered by Proc. No. 3.. 06} is required for a TS chang Performing a USQ determination is conservative for proposed TS change However, this process could contribute to one of the following:

{l}

Implementation of a modification, requiring a TS ch~nge and not canst itut i ng an USQ, without NRC' approval.

{2}

Undue pressure on the preparer to evaluate the change as nol having any reduction in event probability or any reduction in a margin of safety {when the TS change process allows for example, slight reductions in a margin of safety}:

The inspector discussed this with the appropriate supervisor, who referenced an exi~ting TS which required Pl~nt Review Committee review of TS change USQ determinations..

The inspector reviewed more than 25 safety evaluation packages, consisting of a sampling of facility changes, temporary

i

• ---- ---

-

-

- - - - - - - - - - - - - - - -

modifications, and procedure changes from 1991 and 199 In, general, the ~hanges were comprehensive and well documente The following are specific comments:

{l)

Two temporary modification packages-were properly "checked" as changes to the facility,. requiring an unreviewed safety question determinatio. (2)

(3)

(4)

A change to GOP-3 properly referenced the existing TS requirement for operable source range.detector An FSAR update package was*processed on a recently issued NRC safety evaluation regarding ~eismic design~* The plant properly recognized this a~ applicable to the licensing*

basis and added the information to the FSA Two packages involving TS changes had completion dates that.

preceded the official TS issue date issue The inspector cautioned th~ plant to ensure that p~ocedure changes do not precede the implementation date of the T No such inappropriate ~rocedure changes were found, but it appeared *

that the potential for such a mistake existe No violations, devi*tions, unresolved or open items were identifie.

Plant Review Committee CPRCl (37700)

The inspector reviewed the meeting minutes from the follow!ng regularly scheduled PRC meetings: 91-040,91-050, and 92-00 The inspector had previously attended PRC meeting 91-040 and documented his observations in Inspection Report No. 50-255/9200 The meeting minutes accurately represented the meeting discussjo The inspector had previously expressed concern with the extent and *

content of PRC discussions of items approved for the committee by the Plant Safety & Licensing (PS&L) "subcommittee".

The PS&L group does not review items in a committee forma The inspector had qu~stioned whether an adequate sampling of these safety evaluations were being discussed by the PRC to ensure the effectiveness of the subgroup;s revie A review of the PRC meeting minutes showed that approximately 20% of the issues received discussion. Additionally, the PS&L chairman keeps statistics on the number of items processed, forw~rded for PRC review, and rejected. This tracking of performance is considered a strength and appears to resolve the inspector concer.

Licensee Plans For Coping With Strikes (92709)

The company-wide union contract expires on June 31, 1992~ The personnel represented by the union are maintenance {mechanical and electrical) and o~erations. The inspector and Region III managemerit have discussed the planning and potential consequences of a long term strike. The licensee has agreed to discuss with Region III plans fo~

coping with a strike, implementation of the strike plan and resumption of normal operation after the strike when authorization -is granted to prepare for a strik.

Management Interview (71707)

The inspectors met with licensee representatives - denoted in Paragraph 1 - on March 17, 1992, 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 discussed.. The licensee did not identify any such documents or processes as proprietary~

Highlights of the inspection report and items discussed at the exit interview are discussed below: Strengths noted:

(1)

Communications to the NR (a)

Written and oral presentation of the request for the Temporary Waiver of Compliance (paragraph 2.b,

"Temporary Waiver of Compliance").

(b)

Oral presentation pertaining to the stuck fuel bundl (paragraph 7.b, "Outages - Fuel Assembly Attached to Bottom of Upper Guide Structure").

(2)

Management sensitivity to reduced inventory operations (paragraph 2.e, "Operations - Reduced Inventory Operations").

(3)

Inquiring nature of the H.P. Technician stationed at the access control point (paragraph 5.c, "Radiological Controls").

(4)

Performance of outage and shift managers (paragraph 7.a,

"Outages - General").

(5)

Response and recovery from a fuel assembly attached to the bdttom of the Upper Guide Structure (paragraph 7.b, "Outages

- Fuel Assembly Attached to Bottom of Upper Guide Structure").

(6)

Use of a computer search of documents to find references to components when performing safety evaluations (paragraph 9.a, "Safety Evaluations").

(7)

Consideration of indirect Technical Specification conflicts when performing Safety Evaluations (paragraph 9.b, "Safety Evaluations").

-

I I (8)

Comprehensive and well documented changes to the facility, temporary modifications and procedure {paragraph 9.e,

"Safety.Evaluations"). Weaknesses noted:

(1) * Inadequate design change (performed in the early 1970s) to place a portion of the MSIV control circuity in the turbine building (paragraph 2.b, "Temporary Waiver of Compliance").

(2)

Failure to confirm that control circuitry would survive a harsh environment (paragraph 2.b,. "Temporary Waiver of Compliance"). *

(3)

Imp.recise processes and controls for rigging and rigging configuration*(paragraph 2.f, "FHS0-9 Movement of Fuel Pool Divider 'Gate" and paragraph 7.e, "Outages -

Proced~~e Revie~"}.

(4).* Permitting a Radwaste shipment to leave the site that had been leaking wate Compensatory measures had been

. implemented but the consequences, if the measures had*

. failed, were not under$tood (paragraph 5.a, "Radiological Controls"}.

{5}

Potential compromise of contamination control in the general undressing area for the containment undressing area during fuel reconstitutibn ~ctivities (paragraph 5.b, "Radiological Controls"}.

(6}

The licensee never fit-tested the hot-and cold~leg nozzle dams duritig the steam generator replacement project (paragraph 7.c, "Steam Generator Nozzle Dam Installation"}. The open item pertaining to concrete spalling in the Auxiliary Feedwater Pump roomwas discusse The inspector asked if recent activities had affected the *integrity of the walls (paragraph 2.c, 11 Auxiliary Feedwater Pump Room"}. Zebra mussel infestation was discusse The result of an inspection performed at another plant indicate'd the backup piping for aux.il i ary feedwater may be contaminated with zebra musse 1 s (paragraph 7.d, "Outages - Zebra Mussels"}. A potential problem was discussed as it perlains to performing safety _evaluations to identify Unreviewed Safety Questions versus determinations of No Significant Hazards {paragraph 9.d, "Safety Evaluations"}. * The verbal commitment to discuss strike plans with Region III was di~cussed (paragraph 11, "Licensee Plans For Coping With Strikes"}.

I I

.I I

' The Unresolved Item pertaining to procedure compliance was discussed (paragraph 2.f, "FHS0-9, Movement of Fuel Pool Divider Gate," and paragraph 7.e, "Outages - Procedure Review").

21