IR 05000255/1994016

Insp Rept 50-255/94-16 on 940820-1012.Noncited Violations Identified.Major Areas Inspected:Operational Safety Verification,Engineered Safety Feature Sys,Onsite Event of Followup & Security

ML18064A434
Person / Time
Site:	Palisades
Issue date:	10/20/1994
From:	Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18064A433	List: IR 05000255/1994016 ML18064A432
References
50-255-94-16, NUDOCS 9411010130
Download: ML18064A434 (23)

Text

U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report No. 50-255/94016(DRP)

• Docket No. 50-255 License No DPR~20 Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201

Facility Name:*. Palisades Nuclear Generating Facility Inspection At:

Palisades Site, Covert, Michigan Inspection Conducted:

August 20 through October 12, 1994 Inspectors:

M. E. Parker*

s. O'Conl'.lor D. G. Passehl J. A. Isom L. B. Marsh J. A. Lennartz I. N. Jackiw A. H. Hsi a c. E. Brown D. J. Hartland R. A. Langstaff

• Approved* By: /~ft/

.. f?.,/q"f.Kropp, Chief Date Reactor Projects Section 2A

• Inspection Summary Inspection from*Auqust 20 through October 12. 1994:

Report No. 50-255/94016(DRPl Areas Inspected:* Routine, unannounced safety inspection by resident*and regional inspector~ of operational safety verification, ertgineered safety.*

feature systems, onsite event follow-up, current material condition, housekeeping and plant cleanliness, radiological controls, security, safety assessment/quality verification, maintenance, surveillance, engineering and technical support, and report revie Results: Within the 12 areas inspected, no cited violations or deviations were identifie Four non-cited violations were identified (paragraphs and 3).

The following is a summary of the licensee's performance during this inspection period:

Plant Operations The licensee's performance in this area was adequate, The plant operated at full power since startup on June 18, 199 f DR ADOCK 05000255

'UI p~.

'..

S~veral key plant organizations rerirganized effective October 1,. 1994. * The engineering ~nd modifications functions were consolidated under the new ~EC manag~r. The plarit Licensing and Operations.Departments received new manager Auxiliary operators conducted tours and performed evolutions in a thorough and professional manne Shift turnovers and various meetings hosted by the O~erations Department were well conducte Plant operators reported that the addition of a third senior reactor operator on shift was beneficial.* Some operators reported a concern regarding lack ~f a clear chain of command for auxiliary operator A non-cited violation was issued when a reactor operator inadvertently.diluted the primary cool ant system (PCS) to about 101. 5. percent reactor powe The operator set up to dilute the PCS with 30 gallons but became distracted and let the injection conti.nue until some 300 gallons were injected. The proce~s was terminated by the control ro.om superviso Plant operators later

• stabilized the plant at 100 pertent powe Besides inattention to monitoring the core reactivity change, the.licensee found inappropriate training and

.

procedure guidanc The licens~e took appropriate corrective and preventive action *

The inspectors identified some examples of long-standing equipment deficiencies in the auxil hry feedwater system. * Other balance-of-pl ant. items were givento appropriate licensee personnel for followu Safety Assessment/Quality Verification

'*

The licensee's performance in this area was adequat Consumers Power Company's Management and Safety Review Committee (MSRC) for the Big Rock *Point and Palisades nuclear-plants m~t on September 13, 199 The members toured.

the plant, attended daily meetings, and interviewed several staff.* _The MSRC made several positive observations and suggestions for improvement. *

.

.

A non-cited violation was.issued for,a March 14, 1992, event as discussed in Licensee Event Report 255/92021, "Loss Of Containment Integrity During Refueling Due To Simultaneous Opening of System Boundaries."

A non-cited violation.was also issued for an April 2, 1992~ event as disc~ssed in Licensee Event Report 255/92031, "Inadvertent Engineered Safety Feature Actuation Caused By.Inadequate Test Proce~ure." *

Another non-cited violation was issued for an, April 6, 1992, event as discussed in Licensee Event Report 255/92032, ~unplanned Actuation Of The Right Channel Of The Safety Injection System Relays While Performing A Technical Specification Surveillance Test.~*

,;.

Maintenance and Surveillance The licensee's performance in this area was adequat The licensee continued to make progress on reducing the large number of outstanding non-outage corrective maintenance work order The inspector observed several maintenance and surveillance activities associated with emergency diesel generator 1-1 and 1-2 test failures. A detailed discussion is documented in special NRC inspection report 255/94017(DRP).

tnqineering and Technical Support The licensee'~ petformance in this area was adequat On September 1, 1994, members of the NRC's Office of Nuclear Reactor Regulation, the Office of Nuclear Material Safety and Safeguards, and Region III conducted a site visit to review the licensee's actions to resolve numerous dry cask ~torage fabrication and other quality assurance (QA)

problem The inspectors concluded that the licensee had an appropriate plan to resolve the QA problems.

• .. ***

.~ -- DETAILS Persoris Contacted tonsum~rs Power Comp*ny R. A. Fenech, Vi~e President, Nuclear Oper~tioris

• *T. J. Palmisano, Plant General Manager

.

.

• K. P. Powers, Plant Engineering and Modifications Manager R. D. Orosz, Director, NOD Services R. M. Swanson, Director, NPAD

• D. D. Hice, Nuclear Training Manager

• D. W. Rogers, Operations Manager

.

• K. M. Haas, Safety & Licensing Director

• *R~ Kas~er, Maintenance Manager

.

• R. C. Miller, NECO Deputy and Special Projects Manager

• C. R. Ritt, Administrative Manager

• K. A. Toner, Design Engineering Mariager

• K. E. Yeager, Electrical D~sign Engineering Supervisor

• P. J. Gire, Licensing Engineer

• G. J. Szczypka, Diesel Gene~ator System Engineer

• B. A. Low, System Engineering Supervisor D. G. Malone, Shift Operations Superintendent

• L. D. Seamans NECO Engineer

• D. J. Malone, Radiological Services Manager (acting)

• R. A. Vincent, Licensing Administrator..

D. Fadel, NECO Engineering Program Manager J. Broshak, NECO Dry Fuel Storage Engineer

• J. Pomaranski, NECO Project Management ~nd Modifications Manager *

Nuclear Regulatory Commission

• M. E. Parker, Senior Resident Inspector

• D. G. Passehl, Resident Inspector L. B. Marsh, Project Directorate, NRR S. O'Connor, Team Leader, NMSS J. I~om, Senior Resident Inspector, D. C. Cook J. A. Lennartz, Operating Licerising Examiner, RIII

• I. N. Jackiw, Project Engineer, Region III A. H. Hsia, License Project Manager, NRR

C. E. Brown, Resident Inspector, Big Rock Point D. J. Hartland, Resident Inspector, D. C. Cook

. R. A. Langstaff, Reactor Inspector, RII I

• Denotes those attending the exit interview conducted on October 12, 199 The inspectors also had discussions with other licens~e employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and electrical, mechanical and instrument maintenance personnel, and contract security personne.

Plant Operations {71707, 93702}

The plant operated at essentially full power since startup on June 18, 199 Operational Safety Verification {71707}

. The inspectors verified that the facility was being operated in conformance with the license and regulatory requirements and that the licensee's management control system was effective in ensuring safe operation of the plan On a sampling basis, the inspectors verified proper control room staffing and coordination of plant activities; verified operator adherence with procedures and technical specificatiQns; monitored control room indications for abnormalitie~; verified that electrical po~er was available; and observed the frequency of plant and control* room visits by station managemen The inspectors reviewed applic~ble logs and conducted discussions with control room operators throughout the inspection period~ The inspectors observed a number of control room shift turnover The turnovers were conducted in a professional manner and included log reviews, panel walkdowns, discussions of maintenance and surveillance activities in progress or planned, and associated Limiting Condition for Operation {LCO} time

restraints, as applicabl Effective October 1, 1994, several key plant organizations reorganize The engineering and modifications functions were consolidated under the new Nuclear Ingineering and Construction

{NECO} Manage Other plant organizations received new manage~ including the Operations and Licensing Department The inspector conducted plant tours with auxiliary operators

{AOs}.

The.AOs conducted the tours in a professional manner and were very thoroug The AOs responded appropriately ~o directions from the control room in a timely manner and were aware of ongoing plant activities that affected the watch station. The AOs used appropriate procedures when conducting evolutions and responding to annunciator The inspector attended several Operations's Department daily meetings and had the following observations:

Shift turnovers for senior reactor operators {SROs} were conducted in a professional manner and were very effectiv As agroup, all three on-shift SROs turn over to the on-coming SRO The inspector observed a good exchange of information. All off-going SROs provided input to the meetin Performing the turnover in this fashion ensures all on-coming SROs receive the same information. This was considered a strengt. ".**

Each shift conducts a shift meeting following shift turnover~ All of the SROs, reactor operators {ROs},

auxiliary operators {AOs}, and a chemistry department representative were present. A good exchange of information was provided at the meetin The control room supervisor

{CRS} solicited input from each individual watchstander.

. Operations management was also present at these meeting This was likewise considered a strengt *

The inspector observed the Operations' meet~ng that is conducted at 7:30 a.m. each weekday mornin Personnel present at this meeting included Operations Department Superintendents; the -Operations Manager, personnel from Chemistry, Training, and Reactor Engineering departments, and the off-going shift supervisor {SS}. A good exchange of information was provided during this meeting to ensure the various departments understood plant status, maintenance items, planning/scheduling issues, ~nd other miscellaneous items of interest. This meeting was considered a strengt *

The Operations and Maintenance Departments conduct daily meetings to prioritize maintenance issues {termed

"Operations Concerns"}.

The meeting provides better communication to the various Maintenance personnel from operator The litens~e expects the meetings to improve turnaround time on select maintenance*item The operators are aware of this new program, but very few have confidence that maintenance items will be accomplished in a more timely manne This was based partly on some of the longer-term items present on the "Operations Cortcerns" list for maintenance peisonnel to addres *

The Operations Support Superintendent met with all of the maintenance work groups daily.* This was an informal meeting started during the week of August 22, 199 The inspector observed one of these meetings. A good exchange o information was provided at this meeting which allowed all groups concerned to understand why maintenance items were important, which ones had priority, and which groups had the lead for the specific items.. This was considered a strengt The inspectors interviewed a number of operators regarding recent SRO staffing changes involving three SROs assigned to a shift and had the following observations:

All personnel believed the additional SRO {3 versus 2} on shift is beneficial. However, management has not defined the role of the SROs in relation to the AO Therefore, the relationship was not clearly established for the chain of command for the AO The AOs were not sure if they report

• to the nu~lea~ control operatrirs (NCOs), the CRSs, or the SS It was the understanding of some AOs that they should report to the NCOs for normal activities, the CRSs for abnormal items, and the *SSs for emergency item The AOs do not have a cl~ar understanding of whom tri report to and believe a single contact point in the control room would be better for all communication *

Having three SROs in the control room allows the SS to get out into the plant more frequentl It appears that this is occurring and is considered a strengt *

Some SROs that have been placed in the SS position weri having difficulties in adopting to the new role..This is.

expected to improve with time.. Additionally, licensed operator training_is addressing this during team evaluations of the crews during simulator trainin Engineered Safety Feature !ESFl Systems (71707)

During the inspection period, the inspectors selected acces~ible portions of several ESF systems to verify status. Consideratio was given to the plant mode, applicable Technical Specifications, Limiting Conditions for Operation requirements,. and other applicable requirement Various observations, where Jpplicable, were made of hangers and supports; housekeeping; whether freeze protectirin, if required, was installed and operational; valve position and conditions;*

potential ignition sources; major component labeling, 'ubrication, cooling, etc.; whether instrumentation was properly installed and functioning and significant process parameter valu_es were consistent with expected values; whether instrumentation w~s calibrated; whether necessary support systems were operational; and whether locally and remotel~ indicated breaker and valve positions agree *

During the inspection, the accessible portions of the Emergency Diesel Generators 1-1 and 1-2, and Auxiliary Feedwater Trains A and B, were walked dow Some minor material condition deficiencies weie identified th~t are described in paragraph * of this repor Onsite Event Follow-up (93702)

During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the event onsite with licensee and/or other NRC official In each case,.

the inspectors verified that any required notification was correct and timel The inspectors also verified that the licensee

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initiated prompt and appropriate action The specific events were as f o 11 ows: *

September 2. 1994: Emergency Diesel Generator 1-1 Incapable of Carrying Maximum Design Basis Atcident Loads

September 7. 1994: Emergency Diesel Generator 1-2 Incapable of Carrying Maximum Design Basfs Accident Loads A detailed review of both events was performed and documented in special NRC inspection report 255/94017(DRP).

• September 7. 1994: Primary Coolant Dilution Event While performing a minor dilution of the primary coolant system (PCS), the control operator (CO) became distracted from the coritrol panel. With the plant operating near 100 percent power, the CO setup a 30 gallon dilution of the PCS~

to r:naintain Tave temperature and reactor power at a 100 percent valu The dilution. flow rate w~s set at

.

approximately 20 gallons per minut Thus, the evolution should have taken approximately 90 seconds to accomplis After initiating the dilution, the CO became distracted from the control panel to answer the telephon~. As a result, th~

CO did not provide the necessary oversight of the reactivity addition and maintain cognizance of the control panel The CO was not aware that the automatic dilOtiDn isolation would not occur at the lower flow rates. As*a result of the inability of the totalizer to count at the lower*flow rates, the PCS dilution continued at 20 gpm for approximately 15 *

minutes until the Control Room Supe~visor (CRS) noticed ~h increase in the Volume Control Tank (VCT) level and an increase in reactor powe The CRS determined that the primary system dilution was still in progres The dilution was secured by closing CV-2165, Primary Water Control Valve and CV-2155, Makeup Stop Valv Reactor power was noted to be at approximately 102 percent at the tim To reduce the reactor power, boric acid was injected into the PCS, and control rods were inserted to stabilize reactor power, per Off Normal Procedure (ONP)-8, "Uncontrolled

Primary Coolant System Boron Dilution." Once stabilized, the control operators i nject.ed boric acid into the PCS to a 11 ow control rods to be withdrawn to._the norma 1 full out positio In reviewing the event, the inspectors noted that the dilution event lasted approximately 15 minutes with reactor power p~aking at approximately 101.5 percen Minor PCS dilutiori activities are a routine evolOtion conducted by the operating crews to maintain the reactor at full power operation. During these evolutions the operators

• are expected to maintain cognizance of the control panel~,

and monitor reactor power and T~** Standard Operating

. Procedure {SOP}-2A, Revision 22,*dated June 27, 1994~ states in section:

5.2.2 - Anticipate change~ in power level whenever PCS boron concentration is being altere *

5.2.5 - During boration and dilution operations, compare totalizer readings, flow rate verses time and expected changes in tank levels to ensure proper additions are being mad *

1.5.5.a.l - Reactor power and T.v. shall be monitored closely during dilution operation In addition SOP 2A, Section 7.5.5, " Dilution", requires the operator to verify or take the following actions when the primary.makeup water integrated flow indicator {FQIS-0210A}

reaches "0."

• CV 2165, primary makeup water control valve close.

Zero output signal on FIC-0210. Close CV-2155, makeup stop valv As a result of the operator riot properly setting up the dilution flow and monitoring the dilution process, the dilution continued past the expected 90 second operation to over 15 minutes, until noticed by the CR In addition to the operator not maintaining proper overview of his control panel, appropriate training or procedure guidance were not provided to. the operating crew to alert them to the l imitations of the primary makeup water integrated fl ow indicator. Discussions with operators identified that several operators were not aware of the inability of the totalizer to count at the lower flow rate In reviewing the licensee's corrective actions to C-PAL-94-0738, the inspectors noted the licensee identified the following root causes:

• .

Operator inattentiveness to monitoring core reactivit *

Operator disregard to System Operating Procedure guidance.

9 Operator reliance on automatic features of equipment without performing self checking for appropriate response and resul.

Lax communication skills and teamwork concepts by control room personnel in notifying others of their intentions to perform and at completioti of plant/equipment manipulation.

Operator lack of knowledge on instrumentation function and limitation As a result, the licensee initiated several corrective actions to address this event and to prevent recurrence, including:

• The Control Operator was relieved of shift assignment.* Reactor Engineering reviewed this event for potential Technical Specification violations. It was subsequently concluded no ~iolation occurre.

Plant and Operations Management briefed each Operations shift of the event and its significance prior to the shift assuming control room dutie.

The Shift Operations Superintendent imposed a requirement for operators initiating a planned tore reactivity manipulation to communicate their intention to a second licensed operatot.. Work Order 2441411$ was initiated and worked to trouble shoot instrument loop for FQIS-0210A to determine if totalizer is counting accurately and output signal is correc The flow loop was found to be functioning as de~igned with a minor zero shift * *

made to FT-0210.

A caution tag was placed on FIC-0210A to indicate the low flow limitation of the totalize In addition the licensee has initiated several long term corrective actions to enhance activities including procedure upgrades, control room operator aids and additional training. Subsequent to this event, a planned action to

• saturate the new T-518 demineralizer over a two week period to prevent an inadvertent dilution was performed well. The licensee took appropriate conservative measures and held an infrequently performed evolution brief to stress operator attention to detail and strict adherence to the pla **-*

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. *

The dilution incident involved a violation of 10 CFR 50 Criterion V, Instructi~n. Procedures, and Drawings for failin~ to accomplish activities in accordance with protedure The safety significance of this incident was minimal, and the licensee took prompt and appropriate corrective actions to minimize recurrence of the proble Therefore, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria in Section VIl.8(2} of the NRC Enforcement Polic Current Material Condition (71707}

The inspectors performed general ~lant as well as seletted system and component walkdowns to assess the general and specific material condition of the plant, to verify that work requests had been initiated for identified equipment problems, and to ~valuate housekeepin Walkdowns included an assessment of the buildings, components, and systems for proper identification and tagging, accessibility, fire and security door integrity, scaffolding,

• radiological controls, and any unusual condition Unusual conditions included but were not limited to water, oil, or othe~

liquids on the floor or equipment; indications of leakage through ceiling, walls, or floors; loose insulation; corrosiori; excessive-noise; unus~al temperatures; and abno~mal ventilation and lightin Overall material condition was satisfactory; however, the licensee needs to continue with efforts to work off long~standing equipment deficiencies. The inspectors will contjnue to follow the

• licensee's progress in this are *

The inspector reviewed a list of all outstanding corrective maintenance jobs on the Auxiliary Feedwater (AFW} Syste The licensee had twelve corrective jobs outstandin Although this was a relatively small number and none represented an operability conce~n. several work orders were several months ol Examples included:

Work Order No. 24301842 was initiat~d to repair the declutch lever on AFW pump P-SC to "B~ Steam Generator (SG} isolation.valve VOP-0755 on May 27, 1993. This job was designated to be performed with the plant online but was only recently sent to the maintenance planner, 16 months later, on September 20, 199 Work Ordet No. 24303626 was initiated to test the low suction pressure trip on AFW pump P-SC on November 14, 199 Although listed as "corrective," this job was *.

actually a "preventive" maintenance activity to calibrate the pressure switc The grace period for this activity was to expire on November 22, 199 The licensee has begun to take action to reduce the backlog in all area The inspector will *continue to follow the licensee's activities in this are *

The inspector identified other material condition items associated with the balance-of-plant that were forwarded to the licensee for appropriate actio Some examples follo *

The inspector observed numerous oil lea ks from the turbine*

generator seal oil system.* The system engineer was aware of the leaks and stated there are plans in place to repair the oil leaks durin~ a forced outage or during the next refueling outag *

The inspector continued to follow the licensee's actions to address turbine generator alarm problem The inspector noted that several turbine generator excitation trouble alarms were recei~ed in the control roo Investigation found that they were due to annunciator rather than actua turbine generator excitation system problem The licensee plans to conduct inspections and tests on the system during the next refueling outage..

The inspector noted that high pressure turbine heating steam relief valve RV-0591 was weeping and no work request tag was attached to the valv Plant operators wrote a work request to repair the valve~ Hou~ekeepinq and Plant Cleanliness (71707}

The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related equipment from intrusion of foreign matte No significant concerns were identified this inspection perio Radiological Controls (71707}

The inspectors verified that personnel were following health physics procedures for dosimetry, protective clothing, frisking, posting, ~tc., and randomly examined radiation protection instrumentation for use, operability, and calibration.. Security.

Each week during routine activities or tours, the inspectors monitored the licensee's security program to ensure that observed actions were being implemented according to the approved security

• pla The inspectors noted that persons within the protected area displayed proper photo-identification badges and those individuals requiring escorts were properly escorte The inspectors also verified that checked vital areas were locked and alarme *

Additionally, the inspectors also observed that personnel and packages entering the protected area were searched by appropriate equipment or by han O~e non-cited violation was identifie No deviatiohs, unresolved, or inspection followup items were identified in this are.

Safety Assessment/Quality Verification (40500 and 92700)

Consumers Power Company's Management and Safety Review Committee {MSRC)

for the Big Rock Point and Pali~ades nuclear plants met on September 13, 199 The members toured the plant, attended daily meetings, and interviewed several staff. The MSRC made several.positive observations and suggestions for improvemen Licensee Ev~nt Report CLER) Follow-up {92700)

Through direct observations, discussions with licensee personnel, and review Of records, the following event reports were reviewed to determine that reportabilityrequirements were fulfilled,.that immediate corrective action was accomplished, and that corrective action to prevent recurrence had been or would be accomplished in accordance with Technical Specifications (TS): !Closed) LER 255/92001:

Loss Of Air Side Seal Oil In The Electrical Generator Results In A Turbine/Reactor Trip:

On December 9, 1991, the licensee observed that seal oil pressure on the air side of the electrical generator had decreased, and that hydrogen pressure on the main generator was droppin An *..

.

emergencf power reduction was initiated due to th~ continuing loss of the electrical generator hydrogen pressure. A.manual reactor trip and a manual turbine trip were initfated due to increased steam generator level. The cause of this event was a malfunction in the electrical generator seal oil system line due to a plugged filte *

The inspectors reviewed the licensees root cause analysis and corrective actions committed to this LE The licensee initiate several short term corrective actions related to minor equipment problems observed during the power reduction~ prior to re-start of the plant. The inspectors verified that the licensee properly implemented the more significant actions addressed in the LE This LER is close b~

(Closed) LER 255/92011:

Inadequate Electrical Isolation Of Class IE Pressurizer Pressure Indicator Cable:

During a Regulatory Guide 1.97 inspection, it was identified that Pressurizer Pressure Instrument Loop PT-0105A was incorrectly wired to the non-Class IE

primary instrumentation processor and feedwater purity datalogger computers without adequate electrical isolation. This improper installation was attributed t6 lack of definitton of requirements related to electrical isolation which were in place in the early 1980' The licensee confirmed that Instrument Loop PT-0105B was correctly installe~ with adequate electrical isolation provide Electrical isolation was provided in the PT-0105A iilstrument loop in accordance with specification change (SC} 92-052 and work order (WO) 2420120 In addition, modification control procedure AP.03

"Facility Changes," was verified to.include controls to require that electrical separation and isolation be addressed for

..

modifications affecting instrumentation and controls or electrical circuits. This LER is close * (Closed) LER 255/92021:

Loss Of Containment Integrity During Refueling Due To Simultaneoui Opening of System Boundaries:

On March 14, 1992,* with the plant shutdown and refueling operations in progress, the licensee identified that containment integrity had been breached. This condition was due to the simultaneous

. opening of the secondary side handholes on the steam generators and check valve CK-0729 on the auxiliary feedwater lin As *

immediate action, the licensee stopped all refueling operations and reassembled the check valv *

The licensee determined that the root cause of the event was a combination of lack of schedule control, ineffective communication, and pers6nnel erro As preventive action, the licensee refined their refueling sch~dule process to provide more controls for the release.of equipment for repair when.the *

secondary side of a steam generator is ope Although this exent involved a violation of the licensee's TS, it had minimal safety significance because an unmonitored release path to the environment was not create In addition, the licensee properly reported the event and took appropriate

~*

corrective action. Therefore, this. viol~tion will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria in Section VII.B(2) of the NRC Enforcement Policy. This LER is close (Closed) LER 255/92023:

Environmentally Unqualified Terminal Blocks Discovered In An Unidentified Junction Box For Solenoid Valves And Pdsition Switches Associated With The Hot Leg Injection Letdown Valves:

On March 27, 1992, during a ~outine maintenance program inspection of environmentally qualified equipment, the licensee discovered that position switches and solenoid valves for hot leg injection letdown valves CV-3084 and CV-3085 were installed with environmentally unqualified circuit connection In* addition, an unidentified junction box was discovered in the air circuit assembly for the injection letdown valve The cause for this event was determined to be inadequate controls during procurement and documentation of environmentally qualified equipment and the failure to assure that procurement and

.

installation of the air circuit assembly met the requirements of

. 10 CFR 50.4 The unqualified circuit connections were replaced and an inspection of selected equipment was conducted to verify that the required environmentally qualified connections were installe This LER is close (Closed) LER 255/92024:

Inadvertent Opening Of The Station Power Breaker Resulting In An ESF Actuation And Interruption Of Shutdown Cooling:

During b~eaker testin~ activities on the station power breaker on M~rch 27, 1994, the "C" shutdown cooling flow was interrupted when bus "C" was de-energize In addition, the undervoltage condition on bus "C" result~d in both emergency diesel generators starting. Shutdown cooling was interrupted for four minutes during which time core exit temperature increased by about six degree The cause of this event was attributed to personnel erro Work was all owed to proceed contrary to information in the genera 1 operating procedures and beyond that which was authorized by the shift superviso The corrective actions taken by the licensee included:. discussin*g the event and expectations for shutdown risk management; emphasizing the problems associated with deviating from approved work instructions; training of electrical personnel and supervisors on breaker testing requirements, placing caution placards in a more visible location within the breaker cubicle, and revising general operating procedures to clearly define expectations. This LER is close (Closed) LER 255/92025:

Longitudinal Welds On The Thirty-Six Inch Main Steam Line Piping Are Not Included In The Inservice Inspection Program:

The related violation was closed in NRC Inspection Report No. 225/93005{DRS).

This LER is close (Closed) LER 255/92026:

Potential For Overload Tripping Of A Diesel Generator Upon Occurrence Of A Delayed Containment High Pressure Signal: On March 31, 1992, the licensee confirmed that during a small break Loss of Coolant Accident {LOCA) concurrent with a Loss of Offsite Power {LOOP), a condition existed that could cause an overcurrent trip of Emergency Diesel Generator 1-This condition was discovered after Palisades received notification of a similar condition existing at the Calvert Cliffs Nuclear Plan *

During a LOCA event concurrent with the LOOP, three containment

. spray pumps would start when a Containment High Pressure signal

..

occurred and the associated Design Base Accident sequencer had enabled the pump Following a small break LOCA scenario where containment pressure increa~ed slowly and did not reach the containment high pressure setpoint until after the OBA sequencer_

had enabled the containment spray pumps, the pumps would all start when the high pres.sure signal was initiated. Additionally, i thi~ delayed high pres~ure signal occurred just as the OBA sequencer for Bus i~c started the largest major lo~d, the starting current resulting-from simultaneous starting of the~e large loads *

would cause the emergency diesel generator to trip on overcurren The cause of this event is attributed to an oversight in the original plant desig A modification was implemented to prevent simultaneous starting of*

both containment spray pumps on Bus I The modification included a time delay relay in the starting logi.c of the second spray pump to be started on Bus 1-C~ This LER is closed.* (Closed) LER 255/92030:

Inadvertent Starting Of Diesel Generator On Uhdervoltage:

On April 3, 1992, during timing testing of the 2400 Volt Engineering Safeguards Bus 1-C diesel generator starting sequence, both diesel generators inadvertently started. The cause of this event was determined to have been a momentary electrical discontinuity of the potential transformer in the voltage sensing*

circuits for Engineering Safeguards Bus 1-C. This discontinuity apparently occurred when operators unfastened the hinged potential transformer panel in preparation to opening the panel to start the test by pulling the fuse The licensee determined that the fuses are designed* to disconnect when the hinged panel is opene Surveillance test procedures RT-BC and RT-80 have been revised to include detailed instructions regarding fuse operation. This LER is close (Closed) LER 50-255/92-031:

Inadvertent Engineered Safetv Featur~

Actuation Caused By Inadequate Test Procedure:

On April 2, 1992, the Instrument and Controls (l&C) technicians' incorrect installation of test cables, which were also improperly fabricated, resulted in the actuation of the left "Design Basis Accident" sequence The sequencer operation resulted in the running of one of the low pressure safety injection pumps and the containment air cooler fan, V-4 The inspectors *found that the licensee's investigation was well done and thoroug Th~ major causes of the problems were:

Workers connected amphenol plugs of the test cables to the wrong amphenol plugs on the sequencer equipment because of insufficient details provided in the test procedure;

• The I&C technicians incorrectly.terminated the spare conductors on.the test cables so that they were shorted and grounded;

There was inadequate identification of the amphenol test plugs on the sequencer equipmen The inspectors review of the procedures associated with the surveil 1 ance, RT-13A, "Norma 1 Shutdown Sequencer Test - Left Channel," Revision 4, and RT-138, "Normal Shutdown Sequencer Test

- Right Channel;" Revision 4, found that the license had made changes to the procedures so that adequate details were provided to perform the test cable hook-up properl The licensee also made changes to the surveillarice procedures, RT-SC, "Engineered*

Safeguards System~ Left Channel," Revision 4, and RT-80,

"Engineered Safeguards System - Right Channel," Revision 4 because these procedures also required the use of the test cables. The I&C technicians also properly terminated the cables to repair the shorted wire conditio *

The inspector inspected amphenol connections from the sequencer equipment and verified they were labeled to minimize the chance of incorrect hook-ups between the test cable and the sequence Additionally, I&C technicians had performed this procedure without any problems during the *1993 outage.

. Although this event involved a violation of 10 CFR 50 Criterion

• XI, Test Control, it had minimal safety significanc~ because the unit was in cold shutdown and perturbations on the reactor coolant system were small. Additionally, the licensee took appropriate corrective actions which included steps to prevent recurrence of the event. Therefore, this violation will not b~ subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria in Section VII.8(2)

of the NRC Enforcement Policy. This LER is close (Closed) LER 50-255/92032:

Unplanned Actuation Of The Right Channel Of The Safety Injection System Relays While Performing A Technical Specification Surveillance Test:

On Apri-1 6, 1992, '

while performing surveillance RT-80, "Engineered Safeguards System

- Right Channel," the licensee inadvertently actuated the right channel of the safety injection syste The cause of this event was an inadequate test procedure due to an error when a change was made to the procedur The change resulted in testing a different relay, the "first level" undervoltage relay, rather than the one which had been tested during previous tests. Because the "first *

level" undervoltage relay had a built-in 3 second time delay, it did not initiate a loss of offsite power {LOOP) signal before the technicians initiated a safety injection.signal{SIS). This resulted in the incorrect sequence of events for the test in that a safety injection signal was initiated before the LOOP signa lhe ins~ectors reviewed the inve~tigation and found it to be well

. done and thoroug The licensee's corrective actions to.prevent recurrence of the event included adding instructions and steps to procedures, RT-BC, "Engineered Safeguards System - Left Channel,".

Revision 4~ and RT-SD, "Engineered Safeguards System - Right Channel," Revision 4. Also, the licensee updated their design basis document 3.04, to enhance the description of the inherent time delays associated with the bus undervoltage relay The

. inspectors verified that ~hanges made to the surveillance procedures were reasonable to preclude repetition of the even This event involved a violation of 10 CFR 50 Criterion XI, Test Control.* However, the safety sigpificance was minimal, and the licensee took appropriate corrective actions to minimize recurrence of the problem. Therefore, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria in Section VII.B(2} of the NRC Enforcement Policy. This LER is close {Closed) LER 255/92033:

Inoperable Control Room Floor Penetration Due To Inaccurate And Misapplication Of Procedures:

The licensee*

issued this informational LER to document the discovery of an open control room penetration on April 14, 1992, while the plant was in hot standby with the reactor critical. As immediate action, the *

licensee initiated an urgent work order to cap the openin * The licensee subsequently demonstrated that the open penetration did not affect the ability of the control room ventilation system to perform its intended design functio In addition, the licensee determined that fire tours were completed j~ the area of the penetration for the entire time it was ope The.licensee determined that the root cause was a lack of communication between work group In addition, the licensee did not issue a work order to provide control for the open fire barrier, as.required by plant procedure As preventive action, the licensee revised the affected procedure to clarify this requirement. This LER is close {CLOSED) LER 255/93001:

Loss Of Emergency Onsite AC Power Due To Both *Emergency Diesel Generators Being Simultaneously Inoperable:

On January 6, 1993 in preparation for a scheduled Diesel Generator (DG} 1-1 maintenance-outage, a licensed auxiliary operator inadvertently tripped the over-speed trip device for DG 1-2. With the DG 1-1 tagged out of service and DG 1-2 over-speed tripped,

. both DG's were inoperabl DG l-2*was restored to operable within 2 minute *

The licensee disciplined the auxiliary operator in accordance with the Company's progressive discipline policy and reinforced the self-check polic In addition, the over-speed devices for each

generator were tagged with the proper DG identification numbe The inspector verified that these corrective actions were completed. This LER is close CCLOSED> LER 25/93002:

Potential Loss Of Containment Integrity Due To The Failure Of The Emergency Escape Airlock Equalizing Valve:

On March 6, 1993, while performing surveillance procedure (TSSP) S0-48, "Escape Air Lock Penetration Leak Test", the licerisee found that the equalizing valve for the inner door failed to re-seat. This had the potential for providing an unmoni*tored release path and thus violate containment integrity requirement When the outer door was opened to remove strong back equipment from the airlock, containment integrity was compromised for approximately five minute It was determined that the door mechanisms, including the equalizing valves, were not cycled frequently enough to prevent the valve lubricant from drying ou The equalizing valve was repaired and a new lubricant, recommended by the airlock vendor, was used. This LER is close (CLOSED> LER 25/93003:

Plant Shutdown Required By Plant Technical Specifications Due To Primary Coolant System Unidentified Leakage In Excess Of The Technical Specification:

On April 28, 1993, due to increasing leakage from the control rod drive mechanism (CROM)

mechanical seals, unidentified primary coolant system (PCS)

leakage increased to 1.08 gp Technical Specifications state that if unidentified leakage exceeds 1.0 gpm~ the leakage must b identified or reduce the leakage to less than 1.0 gp Since the licensee had scheduled a maintenance outage to repair the rod drive seal leaks later that day, the decision was made to shut the unit down earlier. The CROM mechanical seal packages were repaired and the plant was returned to power on May 16, 199 This LER is close Three non-cited violations were identifie No deviations, unresolved, or inspection followup items were identified in this are.

Maintenance/Surveillance (62703 and 61726) Maintenance Activities (62703)

Routinely, station maintenance activities were observed and/or reviewed to ascertain that they were conducted in accordance *with approved procedures, regulatory guides and industry*codes or standards, and in conformance with technical specification The following items were also considered during this review:

LCOs were-met while components or systems were removed from service; approvals were obtained prior to initiating the ~ork; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; and activities were accomplished by qualified personne *.

The licensee continued to make progress on reducing the large

_numb~r of outstanding non-outage corrective maintenance work order *

-

-

Portio~s of the following mairi~enan~e activities were observed or reviewed:.

Work Order 24414085:

Change out three fuel injection pumps on Emergency Diesel Generator {EDG) *1-1

Work Order 24414086:

Install gaug~s to record engine parameters on EOG 1-1

Work Order 24414087:

Change out fuel injection pumps on EOG l~l per instructions from ~ngineering

• Work Or~er 24414088:

Pe~form visual inspection of air side of turboc~arger on EOG 1-1

Work Order 24414072:

Perform tr6ubleshooting for low ~ow~r output on EOG 1-1

Work Order 24413534:

Raise motor operated potentiometer 1 imits to 64.0 Hz on EOG 1-1. frequency or as high as.

po.ssi bl e

Wo~k Order 24413841:

Perform air fil~er inspection PM on EOG 1-1

Work Order 24411044:

Replace, inspect, and check EOG 1-1 fue 1 injectors

Work Order 24414093:

Inspect and make repairs to EOG 1-2 per work instruction ~I-EPS-M-02

Work Order 24413586:

Remove Temporary Modification 94-073

{modified cr~nkcase cover) on EOG 1-2

Work Order 24412153:

Lo~d and transport VSC 7 t6 Jtorage pad Surv.eillance Activities (61726)

During the inspection perfod, the.inspectors observed technical specification required surveillance testing and verified that te~ting was performed in accordance with adequate procedures, that test instrumentation was calibrated, that results conformed with technical specifications and procedure requirements and were reviewed, and.that any deficiencies identified during the testing were properly resolve *

• . *

The irispectors also witnessed or reviewed portions of the following surveillances:

M0-7A-1. "Emergency Diesel Generator 1...;1 CK"'."6A) II. Rev.32

M0-7A-2. "Emergency Diesel Generator 1-2 CK-68)".

Rev~31

T-348. "1-1 Diesel Generator Peak Load Test". Re *

T.,-349 1 "1-2 Diesel Generator Peak Load Test" 1 Re No violations~ deviations, unresolved, or inspection followup items were identified in this are.

Engineering and Technical Support {83750, 37700, 92720)

The inspector monitored engineering and technical support activities at the site including any support from the corporate office.. The purpose was to assess the adequacy of these functions in contributing properly to other functions such as operations, maintenance, testing, training, fire protection, and configuration managemen *

Dry Cask Storage of Spent Fuel As. described in previous NRC inspection reports, numerous qtiality assurance {QA) problems were discovered during inspections conducted by NRC and by utilities of the Multi-Assembly Sealed Basket {MSB)

fabricator, Sierra Nuclear Corporation {SNC).

In response, the licensee devised a validation program contained in a document entitled "Dry Cask Storage Fabrication Validation Plan." The objective of.the plan was to verify critical attributes in the fabrication of MSB Nos. 1 through 1 On Septe~ber 1, 1994, members of the NRC's Office of Nuclear Reactor Regulation, the Office of Nuclear Material Safety and Safeguards, and Region III conducted a site visit. The purpose was to {l) discuss th~

Validation Plan; {2) to review activities prior to the loading of MSB'

No. 6; and {3) to discuss.activities prior to fabrication of future MSB.

.

The licensee briefed. the NRC members on the corrective actions and root causes related to the previous QA finding The licensee committed at the meeting that loading of MSB No. 6 would not proceed until all corrective actions for all findings had been completed. Approximately 25 items were still open as of the date of the meetin *

The following related documentation was reviewed:

Fabrication Binder for MSB No. 6 {this was a compilation of the permanent QA Records for fabrication activities associated with MSB No. 6);

..

.

...

CMSBI-94-001, Inspection Procedure/Report for the MSB, Revision 1, dated April 1994; *

. Procedure No. MMP 30, Receipt Inspection, Revision 3, dated October 3, 1993;

Checklist for Procedure No. MMP 30, Receipt Inspection Checklist, Revision 0, dated December 7, 1993; and

Quality Control Inspector Qualifications for two individuals responsible for receipt inspection of MSB No. *

In addition, the NRC members reviewed a sampl~ of six previously identified hardware deficiencies on MSB No. 6 to verify that the licensee had an appropriate pl~n to resolve the QA problem The NRC re~iew included the licensee's r~-validation attivities for dimensional characteristics, welding, mat~rial properties, and supplier The licensee identified weaknesses with respect to documentation of welder certifications and weld rod material traceability.. The

- inspectors found that the licensee retested welders with questionable-certification with acceptable results. At th~ time of the inspectors'

review, the licensee was still in the process of closing th~ issue with respect to material traceabilit The inspectots concluded that the QA deficiencies tin MSB N~. 6 were being appropriately addressed. *Based on discussions, the inspectors concurred with the licensee's course of action to satisfactorily resolve the outstanding QA problem No violations, deviations, unresolved, or inspection fol1owup items were identified in this are.

Report Re~iew During the inspection period, the inspectors reviewed the licensee's monthly operating report for August and September, 199 The inspectors confirmed that the information provided met the reporting requirements of TS 6.9.1.C and Regulatory Guide 1.16, "Reporting of Operating information."

No violations, deviations, unresolved, or inspection followup items were identified in this are.

Meetings and Other Activities (30703}

Exit Interview The inspectors met with the licensee representatives denoted in paragraph 1 during the inspection period and at the conclusion ~f the inspection on October 12, 199 The inspectors summarized the scope and

'.. '

r~sults of the inspection and discussed the likely content of this inspection repor The licensee acknowledged the information and did not indicate that any of the information disclosed durihg the inspection could be considered proprietary in natur