IR 05000255/1994011

Insp Rept 50-255/94-11 on 940412-0617.No Violations Noted. Major Areas Inspected:Review & Inspect Issues Identified by Det to Ascertain Whether Any Issues Would Preclude Safe Resumption of Operations

ML18059B141
Person / Time
Site:	Palisades
Issue date:	08/01/1994
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18059B140	List: IR 05000255/1994011 ML18059B139
References
50-255-94-11, NUDOCS 9408220009
Download: ML18059B141 (20)

Text

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/940ll(DRS)'

Docket No. 50-255 Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 License No. DPR-20 Facility Name: *Palisades Nuclear Generating Facility Inipection At:. Palisades Site, Covert, Michigan Inspection Conducted:

April 12 through June 17, 1994 Inspectors:

R. M. Lerch D. S. Butler J. G. Guzman W. J. Kropp M. E. Parker D. G. Passehl Approved By:~~~-;(;(;~;~

Operational Programs Section *

Inspection Summary Inspection from April 12 through June 17, 1994 {Report No. 50-255/94011CDRS Areas Inspected: Special safety inspection to review and inspect issues identified by the Diagnostic Evaluation Team (DET) to ascertain whether any of the issues would preclude the safe resumption of operation The inspection was scheduled to be accomplished before the plant was restarted from a maintenance outag Results:

The issues inspected were determined to either have been adequately resolved by the licensee or did not represent a significant concern for resuming operation of the plan Some issues represented significant programmatic weaknesses that will require action by the licensee to maintain long term operations. Enforcement action was deferred pending issuance of the final DET report and review of the licensee's respons One unresolved item

{Paragraph 3.1.7) w~s identified for a modification made to the thermal margin monitor, and one unreso 1 ved item {Paragraph 3.1.1) concerned use of inadequate isolation design criteria.

9408220009 940812

~DR ADOCK 05000255 PDR

DETAILS Persons Contacted Consumers Power Co~pany CCPCo)

R. A. Fenech, Vice President, Nuclear Operations

• T. J. Palmisano, Plant General Manager R. W. Peabody, Acting Nuclear Engineering & Coristruction Manager S. Y. Wawro, Acting Operations Manager

• D. W. Rogers, Safety & Licensing Director

• Attended the exit on July 28, 199 Other managers and staff were contacted including members ~f Nucleai Engineering and Construction, and System engineerin *

.

. Licensee Actions on Previously Identified Inspector Findings* (Closed)

Inspection Follow-up Item 255/91019-lBCDRSl The electrical distribution safety functional inspection (EDSFI) team was concerned that the licensee's voltage drop and short circuit calculations developed for sizing 125Vdc and 120Vac cables did not consider worst case temperature conditions. The licensee has developed a 125Vdc and 120Vac load data bas DC load flow analysis software was being purihased and the * *

calculations were tentatively scheduled for completion near the end of 1994. *

Following the.DC analysis, the 120Vac load flow a~alyses were tentatively scheduled for completion near the end of.1995.. The licensee committed to use the worst case minimum cable temperature (25°C) for short circuit calculations and maximum cable temperature (90°C) for voltage drop calculations. This was acceptable to the inspector.2 (Closed)

Violation 255/91019-14CDRS)

The EDSFI team identified several *installed motor therma*l overloads (TOLs)

that differed from the TOL setting sheet~. Palisades has had continuing

. problems in controlling TOL device Improperly set TOLs resulted in safety-

. related engineered safeguards room cooler fan motors failing to start during surveillance testing. The new fan motor TOL setting specifications had been developed by the corporate system protection grou However, the process failed to verify by field measurement actual motor running load amperes (RLA),

and sµ,ecified post maintenance testing was inadequate for identifying motor operating margin between the RLA and minimum TOL settin The heater settings for all four engineered safeguards fans were subsequently reanalyzed, revised

• and tested satisfactorily. Approximately 40 TOL and breaker setting changes performed in 1993 were independently reviewed by Sargent & Lund The setting changes were adequately implemente In addition, all safety related 480V motors utilizing TOLs were reviewe All of the motors settings maintained adequate margin between the RLA and the minimum TOL trip settin TOLs utilized in motor operated valve circuits were alarm onl *

As a result of enforcement action inspection report 255/93016, in early 1994, internal TOL setting changes were temp6rarily stoppe The licensee was developing engineering guidance for determining TOL settings. All new setting changes are to be completed accordihg to the specification change proces In addition, safety-related TOL, breaker and protective relay setting changes are to have multi-disciplinary design reviews.. The inspectors concluded the licensee was adequately addressing this concern.and did not identify any irregularities. This item is consider~d close Th~ previous violation for the fan cooler TOL settings, 255/93026-01, remains open. * Review of Start-up Issues from the DET The inspectors reviewed issues identified by the Diagnostic Evaluation Team as potential safety issues that should be addressed prior to st~rting up the plan Inspectors evaluated the issues to establish that the licensee met the design and license bases for the plant, and that all equipment was operable as required by the Technical Specifications, the Final Safety Analysis Report, techn{cal *guidelines, codes and standard The issues and the licensee's short term corrective actions were also reviewed and evaluated to assure the safe operation of the plan *Some of the issues required long term corrective actions. These were inspected to determine that a concern for starting the plarit did not exis Further inspection to fully resolve these issues might be warranted pending the licensee's response to the final DET repor.*

3.1 Electrical Issues 3.. Cable separation The licensee identified in event report E-PAL-94007 that two, 3-foot section, metal, channelization barriers were missing in cable t~ays 3XU109 and 3XU11 As part of the root cause investigation and corrective actions, the licensee initiated the Four Channel Separation Review Projec The project's purpose

• was to review various 4-channel circuit routing criteria, to identify potential deviations, and to correct any identified deviations~ *The project completed the followirig:

rev~ewed tray sections with similar characteristics as tray section 3XU109 which was omitted from the Cable/Raceway Schedule (C/RS)

o walked down 59 out of 247 tray sections and reviewed the remaining trays against the C/RS and layout drawings

evaluated separation issues on a scheme-by-scheme basis, and

evaluated conduits containing 4-channel schemes The cable tray reviews identified no additional missing barriers. The conduit runs were reviewed against the layout drawings and no deviations were

• identified. However, 7 of 127 conduits walked down were identified as having incorrect data in the C/RS, such as unmarked conduits, incorrect conduit sizes

• and wrbng conduit lengths. The project plan recommended that the identified errors be corrected in the C/R However, the licensee indicated.that the remaining I20 conduits were not sch~duled for C/RS information verificatio The inspectors walked down two cable tray sections and one conduit run utilizing C/RS and lay6ut drawing informatio The trays and conduit were installed according to th~ C/RS and drawing The project reviewed 376 cables for 4-cha~nel separatio Walkdowns traced the cabl~ routing of 69 cables ~ither visually or by tone generation *

technique The remaining cables were reviewed by comparing the C/RS to layout drawing The lic~nsee identified 3 cable separation deviations (original construction), I6 non-IE to IE isolation deviations, and 2 items that were resolved by licensing action One temporary modification and I8 specification change pack~ges were implemented to correct the separation and isolation deviation The inspectors reviewed the I9 packages and concluded that the licensee had adequately addressed the identified deviation *

The inspectors were concerned that II of the isolation packages had corrected facility change modifications installed during the I980s. *The licensee *

acknowledged that the deviations resulted from inadequate attention to isolation criteria and that inadequate drawings existed at the time the modifications were installed. The licensee has since developed composite schematic drawings for each preferred AC power inverter distribution br~aker currently in service and tone traced all connections to confirm non-IE to IE isolatio Isolation reviews for all DC breakers connected to IE loads and all RPS/ESF sign~l circ~its have also been complete E~PAL-94007 has severa)

subparts that are still under licensee revie This is considered an unresolved item (255/940II-OI) pending determination of the root cause for using inadequate electrical isolation design criteri~ and the co~pletion of the E-PA.

3. Harmonic distortion of inverter output and impact on safety-related loads Palisades' original constructiori inverters have been in use for ~pproxi~ately

• 27 years. Original installation and testing information was vagu It appears that these units always had high harmonic distortion (>5%).. Inverter specifications used today stipulate that the harmonic distortion content

.should be <5%.

Harmonic distortion is inherent in any nonlinear device, whether it is an inverter (using a ferro-resonant transformer) or loads that contain switching (nonlinear) power supplie Palisades' inverters coritain three parallel SOLA ferro-resonant transformers

. and output filter capacitor The original inverter design contains several weaknesse The SOLA transformers were designed for a sine wave input, whereas, the transformer input is a square wav Square waves inherently produce odd numbered harmonics in a nonlinear devic The original inverter specifications specified a o~7 power factor. The inverter was designed for a o~a power facto As a result, th~ manufacturer added output capacitors as power factor compensatio The inverters typically operate above a 0.9 power factor~ The abo~e items collectively contribute to high har~onic distortion.

. The three SOLA transformers were replaced in I99 Following replacement, a main control room recorder began operating at twi~e it's normal speed.

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Trouble shooting identified that the output capacitors and the SOLA transformers were probably interacting and causing the recorder to speed

~ The 1 i censee removed the output capacitors from inverter No. ED-07. _...

Subsequent testing in' 1994 concluded the output capacitors were causing high harmbnic distortion in the other* inverter Dist6~tion*as high as 10% was observe Tempor~ry capacitor removal decreased the harmonic distortion to approximately~%. The licensee is tentatively planning to remove the other output capacitors during the 1995 refueling outage. *

The licensee reviewed past maintenance hi story to identify any inverter supplied eq~ipment failures that could be attributed to high harmonic distortio No failures were identifie The inspectors concluded the inverters were capable of performing their intended functio. Incorrect torque s~itch setti~q on Mb-3081 CHPSI injection v~lve)

During revision of MOY torque/thrust calculations to incorporate vari~us vendor IOCFR Part 21 issues, new degraded voltage analysis, and other industry issues, it was determined that the existing torque switch (TS) setting of M0-3081 would result in a thrust that was below the minimum reqtiir~d thrus Deficiency report D-PAL-94-099 was generated and the TS settings were subsequently revised.

Completion of the calculation revisions determined that the LPCI discharge valves (M0-3008, 3010, 3012, and 3014) TS settings were set above their thrust windo~ requirements. These valves are 6", 1500# Velan globe v~lves whose active safety function is only to ope (The valves' torque switches are only

~~ed during control of the closing strok Limit switches are used during the bpening stroke, with the TS as backu The valves' ability to open under

design basis conditions has not been a concern.) The high JS setting raised two concerns: first, the resulting overthrusting could challenge the valves'

structural capabilities. Second, under degraded voltage conditions the actuator motor may not be able to deliver the torque required to trip the T The motor would attempt to deliver the torque and potentially burn u The licen~ee generated D-PAL-94-185 to address the issu The structural capabilities were evaluated and the resulting analysis indicated that the

.valves' ability to function at design basis conditions have not been affecte The valves will be left in place and operated ~t a reduced thrust until the 1995 Refueling Outage when the licensee will disassemble and inspect the valve *

To ensure closing of the valve at reduced thrust, as well as during degraded *

voltage conditions, the licensee modified the valves to change the closin~

• control switc Instead of closing on a TS, the valves will close on a limit switch (with the TS as backup).

The change involved wiring changes in the limit* switch compartment, setup of limit switch position, and testing and verifi2ation of valve seating using VOTES diagnostic equipmen Inspectors reviewed the Deviation Report, the structural analysis inputs and results as well as the modification package and related MDV program documentatio The inspectors considered the disposition of the deviation reports to be acceptabl *

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3.1. 4 Voltage drop calculations for 125 Vdc system

__ See paragraph Calibration sheets used by I&C technicians The ins~ectors reviewed the adequacy of the I&C calibration sheet The licerisee acknowledge~ that control valve p6sitiorier calibration sheets contained confusing information; The calibration sheet "control action" area had fail-as-is in the "outpOt on loss of air" and "output on loss of electric".

for control valve position devices POC-0701 and POC-070 Depending on how the instrument technician removed the air source or electrical supply, the valve may fail-as-is or close. The licensee reviewed all POC calibration sheets and clarified the expected control valve positio In addition, this item was.discussed with the I&C technicians and an "expectati~n document" was

. prepared defining wh~t to expect for a gfven control actio * *

The inspectors reviewed 50 additional calibration sheets and concluded the information available to the technicians was reasonabl The technicians indicated they were converting the hard copy calibration sheets to comp~ter generated sheets. This project was tentatively scheduled for completion later this yea Procedure No. 5.04, "Control of Installed Plant Instrumentation (IPI)," controlled revisions to the calibration sheet Changes were approved*

by the I&C superviso If the change involved a setpoint, the specification change process was used to incorporate the chang.1.. 6 Thermal overload relay settings for safety-related pump motors See paragraph 2.2. This issue was also the subject of enforcement action and is* tracked by number 255/93026-0.1. 7 Thermal Margin Monitor CTMM)

A reactor trip occurred on July 3, 1991, during chann A 11 Thermal Margin/

Low Pressure (TM/LP) RPS protection circuit troubleshootin A trip signal was created by the 11A 11 and "0 11 trip logic due to an unidentified short in the 11A" channel dual coil bistable relay. * The short occurred betweeri the test coil (riormally de-energized) arid the trip coil (nbrmally energized);

As a result, installation of the channel 11A" TM/LP bistable unit, following troubleshooting, c~used simultaneous energization of both coils; fnergization of the test coil caused the trip system matrixed pair (

110

) test coil to also energize and a reactor trip occurre Thus, a single RPS component failure caused a reactor tri.

.

• Troubleshooting identified that a lOK ohm resistor was permanently connected between signal common and earth ground.* The resistor completed the electrical path between the shorted bistable relay coil and caused channel "0 11 test coil to also energiz Per USAR Sectiori 7.2.7, "Effects of Failures, 11 the RPS i designed to perform its function with a singl~ failur The RPS analog signal circuits are designed to be ungrounde A single ground on the signal circuit should have no effect. Installation of the TMM without proper input and output isolation deviated from USAR Section 7.2.7 in that a single ground failure c~used an RPS tri *

. E-PAL-91-014K (LER No.91-012) was issued to evaluate the ev~nt and the circuit configuratio The E-PAL concluded that a single additional short to grou~d could cause certain protective action trips to trip nonconservativel As part*of their corrective actions, the licensee proposed to evaluate a method to isolate the TM Isolation was not achieved until. 199 During the 1994 refueling outage, engineering analysis EA-E-PAL-94-037,

"Evaluation of Signal Circuit to Ground Short of Pressurizer Loop," was prepared.to evaluate the impact on RPS trip setpoints giveri the presence of a

. pressurizer pressure loop signal circuit to ground* short and the TMM internal lOK ohm groun The results indicated that the ATWS, Technical Specification high pressurizer pressure, PORV opening, and Technical Specification safety injection setpoints could shift in a noncbnservative direction. This confirmed the results identified in 199 The nonconservative high pressure setpoints deceased the margin between them and the pressurizer safety relief valves, but did not exceed the lowest safety relief valve actuation poin The licensee isolated the TMM lOK ohm ground by installing qualified input and output isolation devices. This returned the TM/LP channels to the RPS configuration previously analyzed in USAR Section.7.2.7. This is considered an unresolved item (255/94011-02(DRS)) pending further NRC review of TMM installatio. The collective impact on Emergency Diesel Generator (EOG)

operability of open items from the EDSFI, DET, and the licensee's*

DBD/SSD Inspectors.reviewed the licensee's responses to these issues, walked down the fuel oil system and discussed the system status with the engineering staf It was concluded that the degraded condition of the system was outside the design basis of the pl~nt and that approval for operation _with the existing conditions and compensatory actions was appropriat The licensee documented these conditions in letters to the NRC dated May 23, June 3, and June 6, 199 This submittal was reviewed and approved in a letter to the licensee dated June 7, 199 * EOG "A" air start motor failure When the EOG failed to start within the time analyzed in the FSAR (lQ Secs) using the "A" air start motor, the licensee replaced the ~otor and sent the removed motor to the manufacturer for analysis. Thre subsequent timed starts were made of the EOG using only the "A'L motor and the start times were.acceptabl The problem of EOG starts exceeding 9.5 seconds was considered corrected for the near ter By letter dated June 1, 1994, the licensee had also committed to declare the EOG ino~erable if the "A" air start motor fails a surveillanc Qualification of the EOG Fuel Oil Transfer system The licensee identified that the fuel oil supply system did not meei its design basis in several ways with respect to general design criteria These conditions were reported in LER 94-00 At the request of inspectors, the licensee submitted a letter describing the compensatory actions taken and a justification for system operability including a plan to return the system to full design capability. This was reviewed

by the NRC and found acceptable by letter dated June 7, 199 The inspectors verified that the compensatory actions specified were in

. plac EOG loading during post accident recovery The inspectors were co~cerned that the EDGs could be overloade~ during a loss of offsite power and post accident recovery~ Peak EOG loading o_ccurs approximately 30 minutes following a large break LOC In response, the licensee re-evaluated the EOG loading calculatio The licensee reviewed the emergency operating procedures and discussed post accident recovery requirements with the licensed operators.* The EOG loading caltulation was revised based on realistic equipment requirement The calculation demonstrated both EOG 1-1 and 1-2 would not exceed th~ir 10% overload short time (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) rating, 3437KV The maximum load tal~ulated for EOG 1-1 was 3108KVA and 3143KVA for EOG 1-In addition, the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> KW rating (2750) was not exceeded. *The calculation also demonstrated that the continuous rating, 2500KW at 3125KVA, would not be exceeded during long term accident recover The maximum load on EOG 1-1 was 2457KW at 2838 KVA, and EOG 1~2 was loaded to 2426KW at 2846KV.

• The calculation adequately addressed potential instrument~tion loop*

errors, indication errors and factored the errors intci the total EOG loading uncertaint To prevent EOG overloading, manual load additions, such as the hydrogen recombiners and the battery charger, were adequately controlled by procedures as to when the loads should be pl~ced on the EDG The inspectors concluded that loading of EDGs during post accident recovery was acceptabl Voltage drop calculations for the air start solenoid The concern was that a DC voltage drop calculation did not exist to determine the available voltage at the EOG air start solenoid The licensee determined the solenoid voltage rating was 74Vd This does not pos~ a low voltage problem, but a high vol~age concer The licensee contacted the solenoid coil manufactur~r and obtai~ed coil temperature rise characteristic The licensee performed calculation No. EA-ELEC-VOLT-028 to determine the coil temperature rise during the EOG cranking cycle (40 seconds maximum).

The results indicated that the four air starting solenoid coils would not overhea The ~olenoids have operated satisfactorily during past EOG testin Seismic qualification of EOG components The lack of seismic qualifications for EOG com~onents such as the day tank, belly tank, auxiliary fill lines, engine exhaust piping for air intake, exhaust crankcase, and the.air compressor gas engine was identified in Design Basis Document, DBD-5.01, Rev 0, open items 1,3, and 1 The licensee performed walk-downs including SQUG walk-downs of the EOG components and evaluated the documentation for the day tan *

While SQUG and other seismic efforts were not com~leted, preliminary assessments concluded that structural integrity was adequate for seismic consideration The inspector~ walked-down the EOG rooms and found no equipment configurations which contradicted the licensee's conclusion~. Usable tank levels *for the day/belly tanks The question of the useable fuel tank volumes was identified in 080-5.01

. Rev 0, open item 1 A special test was conducted which est~blished *

useable levels in the day and belly tank Virtually all of the day tank was demonstrated useable with over 2500 gallons available. This meets the Technical Specification require~ent for having 2500 gallons of fuel available in the day tan The inspectors reviewed the completed test procedure and found it acceptabl Maximum ambient temperature for equipment in the EOG rooms An EOSFI concern for the high temperature performance of EOG equipment

~as listed in 080-5.01~ Rev 0, open item A second room ventilation fan was connected to safety-related power and analysi5 was performed which showed that the two fans would maintain the room at 110 deg~ees. Vendor information and engine~ring evaluation of the components were used to establish that all components would function at that temperatur The belly tank fuel make up valves, which were once the limiting components for the ambient temperature, had been replaced with higher temperatur~ model Inspectors verified the installation of the replacement valves including the day tank makeup valves and reviewed

. documentation for the temperature qualification of other component The fan modification was verified in another inspection (this was an EOSFI concern).

• The EOG's ability to start at the minimum temperature ionditions The.EOGs had never been tested to demonstrate the ability to start at the minimum temperature conditions of 60 F (air) and 90 F (lube oil).

Monthly tests do not verify these parameters prior to EOG startup and these parameters are not alarmed in the control roo This was identified in 080-5.01 Rev 0, open item 1 A special test was conducted in March of 1993 demonstrating EOG

~tart capability with lube oil and jacket water temperatures at 90 degrees which is the lowest temperature at which the EOGs were considered operabl With lube oil and jacket water maintained in standby at.

120 degrees or greater, room temperature was not a concern for starting the EOG Many years of monthly start testing of both EOGs has also demonstrated start capabilities in many ambient condition Lube oii piping design temperatur~ is different than the ope~atin~

temperature This was identified in 080-5.01 Rev 0, open item 22.0.3. The diesel generator lube oil piping was d~signed for 180 The normal system operating ra~ge is 175 to 190 F, with a maximum allowable temperature of 220 F. -This piping was operated at 40 psi below its design value of 135 ps The allowable pipe pressure values *do not change within the system

operating temperature rang The design was therefore appropriat The loading for EOG auxiliarr panels G31 and G21 Cables in EOG auxiliary panels G31 and G21 appeared to be severely -

overloade These conditions were identified in DBD-5.01, Rev 0, open items 23 and 2 Discrepancy Report Nb. F-CG-92-023 addressed that cable No. 8216/801-G31/l (derated to 24.7 amperes) was overloaded to 42.1 ampere The licensee added the cable to the Cable Tray Ampacity Study Project Plan (CTASPP).

The CTASPP will be used to determine if the cable's 90°C rating was exceede An initial evaluation determined the cable was not overloade The cable was carrying 23.5 amperes but was rated to 24.7 ampere This was acceptable to the inspector Discrepancy Report No. F-CG-92-024 addressed that 90°C rated table N Bll6/B01-G21/l (derated to 13.5 amperes) was overlciaded to 42.1 ampere This cable was also added to the CTASP The licensee performed a rough temperature rise calculatio Many bf the input parameters ~ere

~onservative. The cables in the tray were modeled as carrying maximum current and th~ ~able thermal resistivity was set at 400~0 centimeter-degrees Celsius/Watt (cm-°C/W).

Typical cable thermal resistivity for ladder type cable trays were 50 to 100. cm-°C/ The calculated cable temperature rise was 78.8° This appeared acceptable to the inspector The licensee committed to evaluate the overloaded cable concern during the EDSFI inspection. The cable data base was being updated with the correct. cable information. Overloaded cables will be analyzed to determine if their design temperature was exceede The inspectors concluded the licensee was adequately addressing the overloaded cable concer k~

Unbypassed EOG protective trips during emergency EOG* operation Regulatory Guide (R.G.) 1.9, "S~lection, Design, Qualification, and Testing of Emergency Diesel Generator Units *used as Class IE Onsite Electric Power Systems at Nuclear Power Plants," endorses IEEE Std 38 The R.G. requires, in part, that engine-overspeed and generator-differential trips may be implemented by a single-channel trip. All other diesel-generator protective trips should be bypassed or implemented with two or more independent measurements for each trip during emergency EOG operatio Palisades' EOG automatic trips active during emergency ~peration are overload current (1 out of 3 logic}, differential current (1 out of 3 logic), low lube oil pressure (2 out of 2 lcigic), overcrank (1 out of 1 logic}~ overspeed (1 out of 1 logic} and low jacket w~ter pressure through the overcrank relay (1 out of 1 logic). The EOG output breaker is also tripped on an underspeed condition (1 out of 1 logic} and the 2400V bus loss of safeguards power transfer schem The ~nspectors reviewed the USAR which states, in part, that n~ trips on either the generator or the engine are bypassed while engineered safeguards systems are functioniri This was based on Palisades' having two EDGs, each with a full capacity rating, and that single failure

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3.1. 9 criterion is met regardless of which EOG auxiliary component is assumed to fai The inspector~ concluded that even though the Palisades'

design does not meet tpday's standardsr Palisades met the licensing basi Vendor manual updates for the EDGs The in~pectors reviewed the EOG vendor manual (Ml2) to determin~ if the manual was being updated with approved and controlled informatio The manual reviewed w~s signed out to the EOG system engineer; Controlled vendor manuals are considered a design document and the master copies are maintained in the Engineering Records* Center ( ERC).

The system engineer indicated that the EOG manufacturer (General

.Electric/ALCO) was slow to issue updated equipment bulletins. Recently, the system engineer obtained.38 Pali~ades applicable bulletins during a GE/ALCO training cours The bulletins were under review and were being controlled by procedure No. 3.16, "Industry Experience Review Program".

lnaddition to procedure No. 3.16, the licensee uses procedure No; 9.45, "Vendor Manual Control," fbr developing and maintaining Plant Vendor Manual File An informal bulletin review by the system engineer did not identify any bulletins that would affect EOG operabilit The licensee informed the inspectors that other than the system engineer EOG vendor manual, all other onsite controlled documents distributed by the ERC were updated by ERC personne.2 3. Mechanical Issues Missing nuts on a main steam line restraint and other piping support deficiencies The OET inspectors identified several deficiencies in p1p1ng support Each of these was reviewed and evaluated by the license Inspectors reviewed the resolutions to the specific problems as well as the broader corrective

• action The licensee perfbrmed system walkdowns of pipe supports and restraints including a majority of the seismic small bore pipe/tubin Any deficiencies were repaired or evaluated using interim operability criteria.*

Uiing this approach~ no conditions of equipment rendered inoperable were identified~ Large bore piping was part of a program in progress, the safety-related piping review program (SRPRP).

This project was 85% complete; deficiencies were evaluated and correcte No deficiencies resulting in inoperability had been identifie *

3. Potential for component cooling water CCCW) system overpressurization (event v potential)

This is a potential problem, under review by the industry, where a.heat exchanger (for the reactor cooling pump seals) failure could allow reactor coolant water and pressure into the CCW, over pressurizing that syste As a generic ~ssue, no specific response had been requested of licensees. *This was not reviewed as a start up issue.

3. Containment air cooler questionable material condition and questionable functionality/operability The containment air coolers (CACs} are in poor condition and prone to l~akin A number of repai~s have been made including repairs not in accordance with

.the construction cod The CACs are maintained leak free by repairing all lea k Leaks are i dent i fi ed by monitoring containment sump The l ieensee was granted an exception for Section XI non-code repair method As*

corrective action, one CAC has been replaced and the other three will be replaced in the next refueling outag Functionality has been established th~ough engineering analyses and surveillance testin. Concerns with backwater check valves During a review of flood protection for safety-related equipment, the inspectors questioned the adequacy of the floor drain backwater check valve The three rooms that were potentially affected were the auxiliary feedwater (AFW} pump room, and the two emergency diesel generator EOG room Also questioned were the backwater check valves in the containment at the 607 foot elevatio The valves are check valves that are not included in the licensee's check valve inspection program or the preventive maintenance progra The valve~ in the AFW pump room and the EOG rooms were designed to protect equipment located in these rooms by preventing the entry of.water through the drains during flooding condition The valves in the AFW room* were designed to a 10 foot head verses the design accident condition of 23.5.foot hea The licensee subsequently tested the installed valve to determine the as-found conditio Under E-PAL-94-023, the valve was tested to 27.7 foot head (accident condition plus 10%) with satisfactory results, no seat damage and zero leakag The valves in the EOG rooms were evaluated and determined not to have an impact for startup. There is a ~ignificant difference in de~ign *

and the location of equipment such that there is little driving head to move water into the room The.licensee has initiated action to inspect these valves as soon as spare parts can be obtaine The licensee has also committed to include these valves as part of the check valve inspection progra The valves in the containment are installed to prevent water from exiting the cavity flooding system during a LOC This water is there to provide cooling to the vessel cavity to prevent failure of the vessel bottom hea Per 0-PAL- *

94-161, the licensee inspected and cleaned the containment check valve During the inspection, one valve was missing and a second was found with material that may differ from design document Although the recently completed IPE indicates that substantial credit is given to the passive reactor cavity flooding system in preventing reactor vessel lower head melt through in the event of severe core damage, it does not appear that this system is required to mitigate design basis accident, as the reactor cavity flooding system is not discussed in Chapter 14 of the FSAR~ The licensee is evaluating the impact of the backwater check valves on the reactor cavity flooding syste. Test acceptance criteria The inspectors.reviewed ISTs, surveillances, and special tests for the use of acceptance criteria. Acceptance criteria were used.for all tests with the exception of some special tests. These tests were allowed by procedure to be used for data gathering and are not required to have acceptance criteri In all c~ses, the data was used appropriately. Other examples of lack of adherence to test procedures such as failing to meet equ.i pment run times and over ranging test equipment were reviewe In each case, the licensee had determined that there was no impact to the equipment involve The inspectors reviewed the deviation reports generated for these problems and concluded that the actions taken were appropriate. A question with the use of unreviewed

test results was identified with the review -0f s~veral special test Special Test Procedures Due to concerns with the ability to transfer water from the primary coolant makeup tank (T-81) to the condensate storage tank (T-2) by gravity, the licensee performed engineering analysis, EA-E-PAL-94-019. * Technical Specification 3.5.1.e requires a minimum comb.ined inventory of 100,000 gallons of water to be maintained in T-2 and T-81 tanks for the auxiliary feedwater syste Based on this concern, the licensee issued Event R~port, E-PAL-94-.

019, and declared the T-2 and T-81 inoperable on April 7, 199 The licensee's design program identifies three options to verify a desig The options were alternate calculations, *an independent detailed review, or testin The design verification method for EA-E-PAL-94-019 selected by the licensee was a detailed re~iew. However, the licensee did perform a test

• using Special Test Procedure (STP) T-344, "T-81 To T-2 Gravity Feed Test", to validate the flow model used in engineering lnalysis, EA-E-PAL-94-01 Based on the review of this issue the inspectors had the following concerns:

STP T-344 did not require the temperature of _the water in T-2 and T-81 to be obtained during the test to be ~sed as input to

validate the flow model used in the engineering analysi The temperature of the water was an assumption used in the engineering*

analysis. Discussion with the licensee determined that subsequent to the ~est, tempe~ature of the wat~r was 6btained and used in validating the flow mode The method of an independent detailed design review for EA-E-PAL-94-019 met the intent of the licensee's design verification progra However, the licensee was ~ble, due to plant confi~uration, to perform a te~t to ~alidate the engineering analysis, EA-E-PAL-94-019.. Although it was good to perform test T-344, the inspectors noted that the test was not identified as one of the methods used to verify the engineering analysi As a result, the licensee declared the T-2 and T-81 tanks operable before documenting the technical review of the results of test T~

34 The responsible engineer did perform an informal validation of the test results to EA-E-PAL-94-019 but had not documented the results in a manner that would facilitate an independent review by other engineering personne. A similar situation occurred with special test T~345, "AFW Pumps P-8A/B Firemain Backup line Flush" used to verify flow from the fire system to the AFW pump heade The licensee* considered completion of this test an administrative requirement f9r restarting the plant. However, the restart item was closed based on a verbal report of a successful test, prior to a documented technical review. Also, ari ~ngineering analysis EA-A-PAL-94-095,

"Auxiliary Feedwater Pumps Net Positive Suction Head" had been done but the test results had* not been correlated to the anaiysi A preliminary evaluation of the test r~sults by the engineer showed acceptable pressure and flow with a large margi Air o~erated valves CAOVsl Several AOVs on the AFW system were noted to perform poorly due to repetitive seat leakage or failure to operat The licensee had no program for establishing or monitoring AOV performance.* This was a programmatic issu~

that the licensee agreed to addres Any operability issues with individual valves were dealt with in the special system reviews performed by system erigineering in preparation for restarting the plant; The licensee selected a senior system engineer to establish a program for evaluating air operated valve The inspectors attended several system reviews with plant management and concluded that any deficiencies were being recognized and dealt wit. 3.2. 7 Auxiliary Feedwater CAFWl system potential ~vulnerabilities" The inspectors examined the equipment, revie~ed the licensee's response to these issues and discussed them with cognizant engineer A system summary presented by the system engineer to senior management was attended by the inspectors. Collectively and individually, the conditions and actions taken were found acceptable for the safe operation ~f the plan Cold springing of TDAFW pump inlet piping

.Inspectors not~d that the TDAFW pump had alignment jacking bolts engage Further review found that a work order documented cold springing the ~ipe 3/16". Deficiency reports D-PAL 94-104 ind 110 were issue The licensee evaluated the stresses on the piping and turb.ine case. Stresses were within the allowable pipe levels and turbine case strength lfmit Condensate storage tank (CST) temperature limits were raised to 130 degrees

• Partially as a result of steam generator replacement, in 1992 the temperature for the CST went as high as 130 degree A temperature of 120 degrees was used in the FSAR accident analysi An engineering analysis demonstrated that the 130 degree excursion was acceptabl However, the 120 degree limit was determined to be appropriat Inspectors reviewed the administrative controls revised to maintain CST tank temper~ture below 120 degree The changes were found adequate. *

14 Water transfer from the primary coolant makeup tank (T-81) to the CST The DBD-1. 03 Rev 1, open i terns 23 and 29 identified missing and deficient design issues regarding the ability of the T-81 crosstie to the CST to supply enough flo The two tanks together are required to provide sufficient steam generator inventor Inspectors reviewed the results of an engineering model and a ~onfirmation test with the design engineer which demonstrated that flow could be ach1eved through the 3" crosstie valves with the tanks maintained at certain level (See Paragraph 3.2.5) Adm.inistrative controls for maintaining the CST and Primary Coolant Makeup Tank levels, and operator equipment to open the tank AOVs on a loss of air, were established. A review of the completed test run which used nitrogen bottles to open the gravity transfer valves between the tanks was satisfactor Leaking TDAFW turbine steam supply valves The steam supply valves to the turbine driven auxiliary feedwater pump turbine have leaked for many years. This presents several system

operation issue The licensee evaluated.these and determined that they can be compensated for or are not significant.. System operation meets the description of the FSAR and is saf The licensee. has replaced valve trim and is considering valve replacemen Feed-Only-Good-SIG (FOGG) system This.system has been bypassed for Appendix R results, howeve*r, no credit was taken for the FOG Operators rely on AFW flow control valves. *

Technical Specifications revisions bypassing this function have been*

approved by the NR * Alternate AFW steam supply valve This valve performed poorly due to an undersized operato The licensee now maintains the valve ope Its primary function was to provide a low suction pressure turbine trip. This can be accomplished by operators closing another supply valv The licensee planned to relocate the trip

. function to the alternate supply valve in the next outage.. Replacement equipment was also under revie Nonsafety-related nitrogen backup accumulators for A & B AFW train AOVs Nitrogen bottles were not established as seismically qualifie The licensee stated that these were installed for station blackout and appendix R considerations only and were not safety-relate The FSAR supports this ~escription. Further evaltiation of this issue will be tracked as a staff action ite The turbine driven AFW pump is not seismically qualified The addition of the 8C pump eliminated the need to seismically qualify the turbine driven pump by providing two seismically qualified AFW pumps, 8A and 8 *

i~

The alternate steam flow path for the TDAFW pump turbine The alternate steam fl ow path t.o t.he AFW pump turbine iS manua 11 y initiated and fails closed on loss of instrument air. Single failure.*

crit~ria is met by the SA and SC pump The backup steam supply is not

• requ1red by the accident analysi Nonsafety-related atmospheric dump valves (ADVs) or turbine bypass valves <TBVsl For a loss of feedwater event, manual operation of the nonsafety-related atmospheric: dump valves*(ADVs) or turbine bypass valves (TBVs) is required in order to reduce the backpressure in.the S/G tb SS5 psig to allow the SC AFW train to meet the design flow rates of 300 gpm (see AFW 080 1.03, page lS and UFSAR Section 9.7.3.). Without utilization of these non-safety components, S/G backpressure remains at 1000 psig and the SC AFW train can only achieve 245 gpm rated flow, which is not sufficient to meet the UFSAR Chapter 14 accident assumption Significant redundancy is provided by nonseismic, nonsafety atmospheric dump valves and.turbine bypass valve If necessary, tripping the primary cooling pumps reduces SG pressure sufficiently to allow the'

required feed flo *

. The hydraulic calculations for the. fire water AFW supply The AFW 080 identified that the hydraulic calculations for the supply.of fire wat~r to the suction of the AFW pumps could not be locate The licensee performed a NPSH calculation and a fire protection line flush and flowtest to verify that sufficient supply is ~vailable to the AFW pump.

AFW nitrogen bottle stations All of the AFW system nitrogen bottle stations are nonsafety-related, yet are required for system operability by the FSAR and a standing orde However, the FSAR and standing ~rder statements only state that

.the nitrogen is needed for syste~ operability and are not specific regarding when the nitrogen bottles were required~ The nitrogen is only required for Appendix R and SBO which do not require safety~related component.3 Structural Issues Inspectors could not determine the adequacy of the seismic design of.block walls around the vital batteries (Bulletin SO~ll issue).. The licensee had made modifications to the block walls since the original Bulletin S0-11 block

• . wall evaluations were done without performing additional analysi Records were inadequate to verify acceptability of the wa 11 The OET al so identified the presence of cracks in certain b 1 ock wa 11 s and were concerned that there might not be reinforcement in the walls. The battery room walls were found to be the most heavily loaded, and it was decided that if this critical wall was structurally adequate, all the other walls were adequate..

. '

f.*

• • • .

An analysis was performed of the worst block wall on structural strength. A rebar finder and x-rays of the block wall verified presence of reinforcing in the wall. The inspectors reviewed and evaluated the licensee analysis.of the block wall and confirmed presence of reinforcing with x-rays:

Calculations considering the presence of rebar determined that the walls were ~dequately supported.* Operator Training The inspectors attended operator training to ensure th~t operators were trained and knowledgeable of newly implemented procedures, resulting from.

modifications and changes during the.forced outag The inspectors attended a special training session for licensed opetators on May 25, 1994 and an augmented on-shift training session on June 7, 1994

The special training session on May 25, 1993 consisted of walk-throughs of several recently modified procedure change Included in the training were:

• Primary coolant pump status

• Auxiliary feedwater inventory calculation of reserve inventory requirement in EO o Loss of AC power, response per ONP o Steam Generator Tube Rupture, isolation of affected steam generator

• per EOP.. * Diesel Generator operability requirements per Technical Specification 3.7.1 and 3..

.

.

Iri attending this training session.~he inspectors assured that procedure changes were properly addressed_and that appropriate actions were communicated to the operator However, the inspectors.noted that in several cases final *

procedu~e changes had not been completed or approve This resulted in incomplete information being provided. in the training sessio In addition several questions were brought forth by the trainees which could not be*

addressed by the instructors: This resulted in an augmented training session being conducted during the week of June 6,.199 The inspectors attended the

• trainirig session on June.7, 1994 which was conducted to address recent procedure changes and to address concerns expressed in the initial training sessio No additional concerns were identified. *

• Workorder Backlog Review The inspector~ reviewed the licensee's work order backlo The inspectors noted-that the licensee's work order backlog exceeded their target and that no threshold had been established for management action to address this backlo The licensee subsequently provided additional work planners and resources to reduce the workorder backlo Long term action consisted of resource management allocatioh based upon backlog and backlog trendin The licensee conducted a readiness review *meeting as part of their restart pla The inspectors attended that portion of the meeting associated with work order backlog A review performed by the licensee prior to the meeting, evaluated the safety significance of all 2650 outstanding workorder Of the 2650 work orders evaluated, 30 workorders were identified ih which the safety significanc~ was questioned; Based upon further review of the 30 work orders, 8 work orders were added.to the outage scop The inspectrirs evaluated the

30 work orders questioned and concurred with the licensees e~aluation. Of the 8 work orders added to th~ outage scope, none of them wer~ deemed safety significant, but were added, due to the extended outage, to assure additional reliability and availabilit.6 Temoorary Modificit~o~ Backlog Review The inspector reviewed the licensee's installed temporary modifications (TMs)

to ensure that none presented a startup concer The TM backlog at the time of plant start-up consisted of 55 TM Of the 55 TMs, 39 were actually installed; 16 had assigned numbers but were not installed. Most of the TMs were related to maintenance activities with a short duratio Several of the

. TMs were installed on safety related equipment; all were found to be controlled and documente A few TMs were longstanding but due to be removed during the 1995 refueling outag The balance were projected to be removed or

.mad~ permanent before the 1995 refueling outag None of the installed TMs represented a safety or startup concer.7 SIRWT Outlet Valve Actuator Found Degraded Safety Injection and Refueling Water Tank (SIRWT) outlet valve VC-3057 actuator p~ston seal rings were found degraded in March 1994 after a packirig adjustment was made and the valve failed to fully stroke ope The license~

found the actuator blowing by excessively when the valve was in the midpositio The licensee stroked the opposite train valve, VC-3031, t ensure a boric acid flowpath was available from the SIRWT to the primary *

coolant system per GOP-14, hShutdown Cooling Operations."

The licensee repaired the actuator on CV-305 The actuator had not been in the licensee's preventive maint~nance progra The licensee is continuing to evaluate corrective and preventive actions an and will review this issue for generic implications for other "Miller" actuator * Water Shield Barrels Inside Containment Without Proper Evaluation Seven water shield barrels have been in containment at the 590 foot elevation in front of the reactor cavity manway flange for several year The barrels were installed without a Safety Evaluation. The barrels were ~sed fo~

shielding purposes but were never included in the Palisades shielding progra Inspectors were concerned with the barrels having a potential to block the containment sump ~uring a design basis acciden *The licensee performed a safety evaluation based on the following criteria:

1. *

Potential for sump blockage Exposu~e to containment environmental conditions Seismic events ALARA and radiation protection benefits The water shield barrels were made of high density polyethylene (HOPE) and were of 55 and 30 gallon capacity. The barrels were filled with borated and

.18

demineralized water to provide neutron shielding for personnel performing weekly containment entrie The evaluation concluded that the barrels were adequate for shielding purposes in their designated location, will survive containment e~vironmental and seismic events, and do not present a hazard fof containment sump blockage: Removal Of Reactor Bioshield Insulation In 1988, the licensee found that two, horizontal, convection barfier, insulation panels were missing from around the bottom of the react~r vesse The ~onvection barrier insulation panels were designed to prevent hot air from the lower reactor vessel-head area from contacting the uninsulated bioshield concrete wall above the convection barrier around the r~st of the reactor ves~el. A bioshiel~ wall cooling sjstem was installed during original plan construction to maintain the concrete temperature below 165 degrees F and is discussed in Technical Specification 3.1.

'

Technical Specification 3.15 requires that one shield cooling pump and cooling coil be in operation "whenever cooling is required to maintain the temperat~re of the concrete below approximately 165 degrees F."

The licensee discovered the m~ssing-panels while preparing to add access holes to some of the panels for incore dosimetr The licensee issued Deviation Report 88-260 at the time to document their investigation. That investigation.

concluded that continued operation with missing panels was acceptable based on t~mperature measur~ments taken in the vicinity of tl1e insulation; This investigation was inadequate for several reason Most importantly, the licensee's evaluation did not evaluate the effect of the elevated temperatures on the concrete with the missing panel Further, the evaluation did not identify a root cause, did not identify precisely where the temperature

• readings were taken, and did not identify the basis for the insulation panel Additionally, there was no documentation of the plant configuration change, other than in the deviation repor *

In 1993, reactor engineering personnel issued an action item (A-PAL-93-13} at the request of Nuclear Performance Assessment Department (NPAD} personnel to perform a thermal analysis on the biological shield wall to demonstrate compliance with Technical Specification 3.1 During performance of the analysis, the 1 i censee became a*ware that the convection barrier provided by the panels must be present to provide a temperature margin for concrete protectio *

The licensee issued E-PAL-94-026 to document the current evaluatio The licensee returned the insulation panels to their proper as-built configuration during the forced outage that began February 17, 199 In addition, the

licensee began a thermal analysis to determine whether any detrimental effects have occurred to the concret The results of that analysis indicated that no detrimental effects have occurre '

3.10 Weaknesses in ihservice testing of pumps ~nd valves Several weaknesses in performance were identified in the inservice testing (IST} progra The various areas included the relationship between the IS "t program and safety ana~ysis stroke times for MOVs and AOVs, data keeping for*

safety-related relief valves, IST and maintenance of certain check valves, and

~testing df manual valves used in EOP Inspectors reviewed the specific examples noted, equipment status, and the procedures used iri order to ascertain overall IST program performanc The IST program was determined to be acceptable for plant operatio The licensee committed to institute corrective actions for the weaknesses note.0 Unresolved Items Unresolved items are matters about which more information.is required in order to ascertain whether they are acceptable items, violations or deviation Two unresolved items diiclosed during the inspection are discussed in Paragraphs 3.1.1 and 3..0*

Exit Interview (30703)

The irispectors met with the licensee representatives denoted in paragraph 1 during the inspection period and at the conclusion of the inspection on July 28, 1994; The inspectors summarized the scope and results of the inspection and discussed.the likely content of this inspection repor The licensee acknowledged th~ information ~nd did not indicate that any of the information disclosed during the inspection could be considered proprietary in nat~r