IR 05000255/1994018
| ML18064A529 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/14/1994 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18064A528 | List: |
| References | |
| 50-255-94-18, NUDOCS 9501030193 | |
| Download: ML18064A529 (22) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION *
REGION I II Report No. 50-255/94018(DRP)
Docket No. 50-255 License No. DPR-20 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson~ MI. 49201
. Facil~ty Name:
Palisades Nuclear Generating Facility Inspection At:
Palisades Site, Crivert, Michigan Inspection Conducted:
October 13 through December 2, 1994 Inspectors:
M. E. Parker D. G. Passehl J. M. Jacobson J. L Belanger
.,
Approved By:
S>-- --2-:Z<C];,<..-fi-yq:.W';-~J: Kropp/ Chief J. A. Gavula G. Replogle R. M. Lerch I. N. Jackiw
- Reactor P~jects Section 2A Inspection Summary Inspection from October 13 through December 2, 1994 (Retiort No. 50-255/94018CDRP))
I 2 - I y -7*y-Date Areas Inspected:
Routine, unannounced safety inspection by resident and regional inspectors of actions on previous ihspection findings, operational safety verification, engineered safety featured systems, onsite event followup, current material condition, housekeeping and plant cleanliness, radiological controls, security, safety assessment/quality verification, maintenance activities, surveillance activities, engineering and technical support, Temporary Instruction {Tl} 2515/125 - Foreign Material Exclusion Controls, report review, and meetings.
- Resul.ts:
Within the 15 areas inspected, no cited violations or deviations were identified.
One noncited violation was identified (paragraph 4.b}.
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 has operated at full power ~ince startup on June 18, 1994.
9501030193 941214 PDR ADOCK 05000255 G
On November 3, 1994, the licensee reported a potential bomb threat. Details were provided to the NRC headquarters office and other appropriate federal, state, and local government authorities. The licensee evaluated the potential-threat and implemented appropriate increased security measures.
The licensee continued to experience problems with seal l~ak~ge on chargtrig -
pump P-55A.
In addition, the licensee saw an increase in shaft seal leakage from primary coolant pump P-500.
The licensee. is appropriately addressing these issues.
Operability decisions were found to be untim~ly on two occasions, wh~ri oil samples for the auxiliary feedwater pumps were found in the critical range.
Condition reports were generated documenting th~ condition after another sample of the oil was performed, approximately one month later.
The inspector held discussions with the licensee regarding the discovery of a very small amount of tritium in the feedwater purity -building heating boiler condensate return line. The licensee's current actions to resolve the issue and investigate the source of the triti~m appeared satisfactory.
No radi6active effluent limits were exce~ded. However, the licensee was slow in implementing actions to irivestigate this issue since some licensee personnel had known about the presence of the tritium since April 1994.
Also, the licensee was slow to take action to monitor the release path of the tritium.
Safety Assessment/Quality Verification The licensee's performance in this area was adequate.
Consumers Power Company's Management and Safety Review Committee (MSRC) for the Big Rock Point and Palisades nuclear plants met on November 8, 1994.
The members toured the Big Rock Point plant, attended daily meetings, and interviewed several staff.
A noncit~d violation was issued during closeout review of a 1992 Licensee Event Report.
The violation involved access to the plant protected area by an unauthorized individual.
Maintenance and Surveillance The licensee's performance in this area was less than adequate.
The inspector noted several problems that occurred during work performed on engindering safeguards room air compressor, C-6A.
The problems involved lack of proper maintenance, lack of rigorous design review, and a weak receipt inspection.
One positive observation was made in the participation of maintenance first line supervisors into field activities.
The inspector observed an example of poor communications between two control room operators during a.post maintenance test on auxiliary feedwater pump P-8B steam driver, PC-0521A.
The insp.ectors conducted a detailed review of.the licensee's foreign material exclusion (FME) program per the guidance provided in NRC.Inspection Manual Temporary Instruction 2515/125.
The inspectors found that the 1 ic*ensee's FME program was.adequate.
- Engineering and Technical Support The licensee's performance in this area was adequate The inspectors reviewed the licensee's engineering analyses of weld flaws in Multi-Assembly Seal~d Basket No. 4.
The inspector found the licensee's evaluation to be conservative in every respect, with substantial margin agatnst failure.
The inspectors met with licensee engineers to discuss some modifications related to the licensee's Safety Related Piping Reverification Program {SRPRP)
activities.
Some system ehgineers showed a lack of knowledge about o~g~ing modifications and lacked a questioning attitude on equipment operability.
- DETAILS 1.
Persons Contacted Consumers Power Company R. A. Fenech, Vice President; Nuclear Operations T. J. Palmisano, Plant General Manager
- K. P. Powers, Plant Engineering and Modifications Manager R. D. Orosz, Director, NOD Services R. M. Swanson, Di rector, NPAD *
- D. D. Hice, Nuclear Training Manager
- D. W. Rogers, Operations Manager
- S. Y. Wawro, Outage and Planning Manager K. M. Haas, Safety & Licensing Director
- R. B. Kasper, Maintenante Manager
- R. C. Miller, NECO Deputy and Special Projects Manager
- C. R. Ritt, Administrative Manager
- J. C. Griggs, Human Resource Director
- R. J. GerlingjReactor and Safety Analysis Manager
- J. L. Hansen, Plant Support Engineering Mahager
. -*D.. J. Vandewalle, System Engineering Manager P. J. Gire, Licensing Engineer
D. G. Malone, Shift Operations Superintendent
- D. J. Malone, Radiological Services Manager
- R. A. Vincent, Licensing Administrator
- D. P. Fadel, NECO Engineering Program Manager J. P. Broschak, NECO Dry Fuel Storage Engineer
- J. P. Pomaranski, NECO Project Management and.Modifications Manager *
Nuclear Regulatory Commission
- M. E. Parker, Senior Resident Inspector D. G. Passehl, Resident Inspector J. M. Jacobson,.Materials and Processes Section Chief, Riii J. L. Belanger, Safeguards Inspector, Riii J. A. Gavula, Materials and Processe$ Inspector~ Riii G. Replogle, Maintenance and Outages Inspector, Riii R. M. Lerch, Operational Programs*Inspector, Riii J. A. Isom, Senior Resident Inspector, D. C. Cook I. N. Jackiw, Project Engineer, Region 111-
- Denotes those attending the exit interview conducted on December 2, 1994.
The inspectors also had discussions with other licensee employees, including members of the technical and engineering staffs, reactor and auxiliary operators, shift engineers and e)ectrical,*mechanical and instrument maintenance personnel, and contract security personnel.
2.
Action on Previous Inspection Findings {92701, 92903)
a.
(Closed) Inspection FolloWup Item (50-255/88012~03(DRS)): Post fire safe shutdown procedure, ONP 25.1, had inaccuracies in the table of contents and was not user friendly. *This procedure had been revised and reorganized several times since 1988.
The.latest revision was Revision 4, dated March 3, 1993, which included a
- ~inimal Table of Contents, only a few pages of steps, and ~11 the
. potential fire areas described in *attachments.
The previous NRC concerns had been eliminated.
In 1994, the litensee initiated an extensive review of fire protection requirements and how these requirements were met.
This effort will take many months and may result in significant changes to fire protection at the site.
This item is closed.
- b:
(Closed) Unresolved Item (50-255/90015-0l(DRSl):
The root cause of o~erstressed reactor coolant drain piping was questioned. This issue was ~iscovered before the licensee initiated the Safety c.
. Related Piping Reverification Program {SRPRP).
The purpose of this program was to identify similar discrepant piping condjtions.
Based on the licensee's ongoing SRPRP efforts, no additional steps
. were needed to address this issue.
Thi~ item is closed.
(Closed) Unresolved Item C50-255/90015-02CDRS)):
Corrective actions to address desi~n control deficiencies were questioned.
This item was identified prior to the inspections for the steam generator replacement project. Additional design control deficiencies were identified in this later inspection _and the*
licensee implemented significant corrective actions to address *
very broad design control issues. See NRC Inspection Report 50-255/90025 for addition~l information.
Based on the license~'s actions, this item is no longer relevant and is closed.
d.
{Closed) Violation C50-255/91026-01CDRS)):
Inaccurate information was provided to the NRC in documents related to enforcement issues.
The licensee's response to the Notice of Violation
- described the reason for the violation as p_ersonne l errors on the part. of information preparers or reviewers. Corrective attions
- included plant staff discussions emphasizing the need to communicate both completely and accurately with the NRC, and issuance of guidelines for improving the quality of licensing.
submittals. Discussions with NRC personnel involved with the*
licensee did not identify any further instances where inaccurate or misleading* information was provided to the NRC.
This item is closed.
e.
(Closed) Violation C50-255/92004~02CDRS)): This violation pertained to eight Raychem splices that were not environmentally qualified {EQ) in accordance with 10 CFR 50.49 by the November 30, 1985, deadline.
The licensee's response to the violatibn, dated June 5, 1992, identified the root cause and delineated corrective actions. The inspectors discussed the corrective action with the
f.
g.
h.
licensee and reviewed historical documents to determine if similar problems were identified; The corrective actions app~ared acceptable and the inspectors identified no similar examples of non-qualified splices~ This item is closed.
<Closed) Inspection Followup Item C50-255/92004-05CDRSll:
This item pertained to numerous activities, associated with the Regulatory Guide. {RG) 1.97 program, that were not complete at the time of the original RG 1.97 inspection. The inspectors verified that the necessary items were completed and a sample of the items appeared to be acceptable. This item is closed.
CC16sedl Violation C50-255/92011-02CDRSll:
This violation cited a failure to take prompt corrective actions to address numerous contractor identified EQ deficiencies {NRC Reports 50-255/92011 and 50-255/92017 and Enforcement Action 92~074). When the contractor's work was finally evaluated, over one year after the report was submitted, numerous pieces of safety-related equipment were determined to be inoperable {including the main steam isolation valves). A m~jo~ contributor to the violation was the lack of a thorough and timely, engineering review of the contractor's work.
The NRC inspectors verified that all corrective actions associated with hardware modifications and EQ deficiencies were complete..
Other concerns related to the inadequate oversight of contractor workwere also addressed. Although some improvement was observed
{including increased supervision of contractor activities and new requirements to formally document and address contractor identified deficiencies}, a general concern with contractor oversight was identified by the NRC Diagnostic Evaluation Team and is being tracked as inspector followup item 50-255/94014-51{DRP).
The NRC will continue to monitor the licensee's progress toward resolving contractor oversight deficiencies in response to the noted followup item. This item is closed.
(Closed) Violation (50-255/93032-0lCDRPll:
This violation invrilved the licerisee's failure to submit Licensee Event Reports
~ithin the requir~d time.
The licensee failed to submit required LERS within 30 days of an event during 1990, 1991, 1992, and 1993.
The root cause was attributed to lack of process ownership and inadequacies in the process which did not require any follow-up checking of corrective action documents to ensure proper reportability decisions were being made.
The corrective actions taken included revising administrative procedures to designate the Licensing Administrator as having the responsibility for overview of the reportjbility determination process, determining plant staff training requirements, and requiring management review of all event report evaluations. This item is closed.
- No violations, deviations, unresolved, or inspection followup items were identified*in this area:
3. *
Plant Oper~tions (71707, 93702)
The plant has operated at essentially full power since June 18, 1994.
a.
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 plant.
On a sampling basis, the inspectors verified proper control room staffing and coordination of plant activities; verified operator adherence with procedures and *
technical specifications; monitored control room indications for abnormalities; verified that electrical power was available; and observed the frequency of plant and control room visits by station management; The inspectors reviewed applicable logs and conducted discussions with control room operators throughout the inspection period. The inspectors observed a number of control room shift turnovers.
The turnovers were conducted in a professional manner and includ~d log reviews, panel walkdowns, discussions of maintenance and surveillance activities in progress or planned, and a~sociated Limiting Condition for Operatioh time restraints, as applicable.
During a review of Condition Report (CR) c~PAL-94-0883 that pertained to auxiliary feedwater pump/motor (P-8C) oil quality, the inspectors reviewed the licensee's operability decision.
The CR was initiated to document the high ferrous and copper particle count in the oil sample.
The inspectors noted that ferrous and copper particle count exceeded the critical range; however, the licensee considefed pump P-8C operable based upori a more recent*
oil sample which indicated acceptable ferrous and copper particle count. Subsequently, CR C-PAL-94-0890, "Auxiliary Feedwater Pump Outer Bearing Out of Specification (P-8A/P~8B)," was initiated to document a simi.lar condition for the P-8A and P-88 auxiliary
feedwater pumps.
In both cases, the total ferrous particle count was again found in the critical range and the oil was sampled again and brought down to the cautionary range.
The licensee corisidered both pumps operable based upon a more recent oil sample and acceptable vibration readings.
Further discussions with the sys.terns engineer noted an erratic trend in the oil samples for the auxiliary feed pumps.
This appears to be due to the method of obtaining the oil samples.
The operators appear not consistent _in the method of obtaining the samples, therefore, the data can not be utilized to maintain an effective trend.
The licensee has been aware of this concern, and was looking at several alternatives to ensure the samples obtained were representative of the actual oil conditions.
The inspectors were additionally concerned with the timeliness of the CR.
The CR wa~ initiated to document.the.results of the oil sampling following a retest of the oil, *nd was not initiated following an oil sample report in the critical range, approximately one month earlier. The inspectors will continue to follow the licensees actions to improve the -0iJ sampling program.
b.
Engineered Safety Feature CESFl Systems {71707)
During the inspection period, the inspectors selected acce*sible portions of several ESF systems to verify status. Consideration was given to the plant mode, applicable Technical Specifications, Limiting Conditions for Operation requirements, and other applicable requirements.
Various observations, where applicable, were made of hangers and.
supports; housekeeping; whether.freeze protection, if required, was installed and operational; valve position and conditions;
. potential ignition sources; major component labeling, lubrication, ccioling, etc.; whether instrumentation was properly_installed and functioning and significant process parameter values were
~onsistent with expected ¥alues; whether instrumentation was.
calibrated; whether necessary support systems were operational; and whether locally and remotely indicated breaker and valve positions agreed:
During the inspection, the accessible portions of the train "A" of*
High Pressure Control Air and train "A" of Low Pressure Safety Injection were inspected.
The following items were identified during the walkdowns:
Final Safety Analysis Report {FSAR) Table 9-10 fd~ntifies all valves in the plant operated by high pressure air. High pressure air operated valve CV-0521A {Steam Supply Valve to Turbine-Driven Auxiliary Feedwater Pump P-88), was not indicated in FSAR Table 9-10 as being operated by high pressure air.
- The control room. "high pressure control ai~ compressor hi-lo pressure" alarm was in and out for several days while the east engineered safeguards room high pressure air compressor, C-6A, was out of service for repairs. During this time the high pressure air in the east engineered
safeguards room was supplied by the turbine building high pressure air compressor, C-6C.
Plant design and procedures appropriately addressed. this lineup.
However, the alarm was in about 60 percent of the time as a result of different start and stop setpoints between C-6A and C-6C.
A shift supervisor ~tated that the necessity for ha~ing different
. setpoints on C-6A and C-6C was under review.
The inspector followed up with the system engineer who was unaware of such a review.
The licensee agreed to evaluate and take appropriate action as needed regarding the above items.
c.
Onsite Event Follow-up (93702}
During the inspection period, the li£ensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72.
The inspectors pursued the events onsite with licensee and/of other NRC officials.
In each case, the inspectors verified that any required.notific~tion was correct and timely.. The inspectors also verified that the licensee initiated prompt and appropriate acttons. The specific events were as follows:
On November 3, 199'4, the l i censee reported a potential bomb
. threat. Details were provided to the NRC headquarters office. The licensee notified other appropriate federal, state, and local government authorities. The licensee evaluated the potential threat and implemented appropriate increased.security measures.
- *
On November 23, 1994, the licensee reported to the resident inspector the loss of the "F" bus in the offsite electrical power system.
The loss of the "F" bus was due to the failure of offsite power breaker 27F7 to transfer fast enough after sensing a fault o.n its supp 1 y l i ne from D. C.
Cook Unit 2.
The inspector will continue to follow the licensee's corrective and preventive actions in response to this event.
d.
Curreht Material Condition (71707}
The inspectors performed gener~l plant as well as selected 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 evaluate housekeeping.
Walkdowns *included an assessment of the buildings, componertts, and systems for proper identification and tagging, accessibility, fire and security door integrity, scaffolding, radiological crintrols, and any unusual condition~. Unusual.
conditions included but were not limited to water, oil, or other
'liquids on the floor or equipment; indi~ations of leakage through*
ceiling, walls, or floors; loose insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lighting.
'.
Overall material condition was ad~quate. Some minor items identified are described below.
The inspector checked work request *tags for auxiliary.
feedwater pumps P-8A and P-88 to ensure the items were entered into the l iCensee' s work control system.
Most work *
requests ~ere appropriately entered fn the work control system. The inspector identified one work request that had not been entered..Work Request 249384 was initiated on April 16, 1994, on auxiliary feedwater pump P-:8A.
The request was to repair a smal1 oil leak on the inboard motor bearing s~al. This item was tiot entered into the licensee's work control system.
The inspector gave this item to the system engineer for followup.
There was a large amount of scaffolding and other ~quipment located in the engineering safeguards rooms for the licensee's Safety Related Piping Reverification Program (SRPRP) activities. The licensee performed several pipe support modifications as a result of walkdowns associated with the SRPRP.
The inspettors met with licensee engineers tci discuss some modifications to ensure that the licensee performed proper operability evaluations on affected equipment.
The inspectors found no operability problems.
However, some of the.system engineers showed a lack o~
knowledge about on~oing modifications and lacked a questioning attitude on equipment operability.* *
The-inspector iontinued to follow the license~'s actions to.
addre~s seal leakage problems on charging pump P-SSA.
The licensee has removed P-SSA from service every few weeks to repack the pump because of excessive seal leakage.
The licensee is exploring several options to resolve the issue.
The material condition of P-55A was an Unresolved Item issued in a previous NRC inspection report (255/94012-02).
The licensee has responded in writing describing what actions will be taken to improve the material condition of the charging pump and to reduce the out of service time and potenticil challenge to.the Technical Specification Limiting Condition for Operation.
- Primary coolant pump P-500 exhibited signs of degraded shaft seals during this inspection period.
The leakage has
remained within acceptable limits and the licensee has been appropriately monitoring the leakage for significant changes; The licensee has plans in place to replace the seal during the next refueling outage.
Plant procedures appropriately guide operator actions should a significant increase in seal leakage occur.
e.
Housekeeping and-Plant Cleanliness {71707}
The inspectors monitored the status of housekeeping and plant cleanliness for fire pr6tection and protection of safety-related equipment from intrusion of foreign matter.
No significant concerns were identified this inspection peri~d.
-f.
Radiological Controls {71707}
The inspectors verified that personnel were following health physics procedures for dosimetry, protective clothing, frisking, posting, etc., and randomly.examined radiation protection instrumentation for use, operability, and calibration.
The inspector held discussions with the licensee regarding the discovery of a very sma 11 amount of tritium in the.f eedwater purity building heating boiler condensate return ~ine. The licensee's current actions to resolve the issue and investigate the source of the tritium appeared satisfactory.
No radioactive effluent limits were exceeded. However, the inspector had the following concerns£
The licensee was slow in implementin~factiOns to inv*estigate this issue sine~ some licensee personnel had known about the presence of-the tritium since April 1994;
-
I
-.
'
. -
-
-
The licensee was slow to take action to monitor the release path of the tritium, which ultimately dischar~es to Lak~
Mithigan.
-The inspector will continue to follow the licensee's actions to resolve this issue.
g.
Security Each week during routine activities or tours, the inspectors monitored the license~'s security program to ensure that observed
. actions were* being* implemented according to the approved security plan.
The inspectois noted that persons within the protected area displayed proper photo-identification badges and those individuals requiring escorts were properly escorted.- The inspectors also verified that checked vital areas were locked and alarmed.
Add it i ona 11 y, the inspectors a 1 so observed that personne 1 and
_
packages entering the protected area.were searched by appropriate equipment or by hand. _ The inspectors were appropriately briefed
- and monitored the licensee's actions on the ~otential security -
threat referenced in *paragraph 3.c.
No violations, deviations, u_nresolved, or inspection _followup items were identified in this area.
4.
.Safety Assessment/Quality Verification (40500 and 92700)
a.
Management and Safety Review Committee CMSRC)
Consum~rs Power Company's MSRC for the Big Rock Point and Palisades nuclear plants met on November 8, 1994.
The members toured the Big Rock Point plant, attended daily_ meetings, and
- interviewed several staff. The inspectors reviewed the meeting minutes~
b.
Licensee Event Report CLER) Follow-up (92700, 81502)
Through direct observations, discussions with licensee personnel,*
and review of records, the following event reports were reviewed to determine that reportability requirements 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}:
1)
. 2)
(Closed) LERs 255/92-006. 255/92-012. 255/92-013.
255/92-018. and 255/92-019: lnadegyate Environmental Qualification CEQl*of Safety-Related Equipment:_ These LERs pertained to nu*merous pieces *of safeti related equipment,* in harsh environments, that were not environmentally qualified.
The issues, reported in the LERs, were the focus of a reactive NRC inspection (Inspection Report 50-255/92011),
which resulted in.the issuance of a Notice of Violation for inadequate ~orrective actions (see item 50~255/92011-02 which is closed in this report}.
The LERs were evaluated in*
detail by the inspectors in association with the noted reactive inspection. During this inspection, the inspectors.
verified that all corrective steps were complete and that no similar problems were experienced. These LERs are closed.
(Closed) LER 92-014: Unauthorized Individual Granted
.
Unescorted Access to Protected Area Due to Personnel Error by Security Badging Office: During a routine badge pre1ssuance review of paperwork for unescorted access, a security badging clerk failed to identify that the fitness for duty (FFD} test results had ~ot been received and mistakenly badged the individual. The individual did enter the protected area for approximately fifty-nine minutes before Security was notified of the positive pre-~ccess test results on the individual~ The individual was located and unescorted out of the protected area. Unescorted access was revoked.
. As reported in the LER, the cause of the badgin~ error was-a persorinel error (lack of attention to detail}. lhe.
inspector determined that this event was an isolated
occurrence and was not willful. There were no prior similar
- events nor have there been repeats in the following two and a half years.
The granting of unescorted access to the protected area without negative drug test results is a licensee identified*
vi~l~ti~n of 10 CFR Part 26.24{a){l) with low safety significance.
The individual was.in the protected area for less than an hour and the individual's badge was not
prograrmned for access to any vital area. The individual was also accompanied by other contractor employees for the majority of the time in the protected area.
Corrective actions includ~d a review with all security badging personnel *addressing the need for attention to detail. Additionally, the Badge Number Listing Log was revised to include a column fo~ listing the FFD testing date which required an additional check that FFD test results have been received prior to the badge being issued. This form was subsequently replaced with the "Unescorted Access Authorization" envelope which also documents receipt of FFD test results. These corrective actions were appropriate and effective in correcting the problem.
-
This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Polity. The event wa~ appropriately *
reported to the NRC per 10 CFR Part 73, Appendix G, Item l(b). This LER is closed.
- 3)
. (Open) LER 93-013:
Loss of Emergency Onsite AC Power to Both Emergency Diesel Generators Being Simultaneously Inoperable~ During testing of diesel generator {DG) 1-1 on April 27, 1993, DG 1-1 load dropped to zero and the diesel generator was de~lared inoperable.
To meet technical specification requirements, DG 1-2 was.started and loaded to verify operability; however, by paralleling DG 1-2 to the electrical distribution grid to accept load, DG 1-l was rendered inoperable for five minutes. Since both diesel generators were simultaneously inoperable, Technical Specification 3.0.3 was entered and an Unusual Event was declared.
- The licensee plans to submit a revision to the electrical section of the tech specs. This item will be reviewed during a future inspection. This LER is open.
4)
(Open) LER 255/94002: Inadvertent Containment Spray Pump Actuation During the Performance of a Tech Spec Surveillance Test:
On January 26, 1994, while performing surveillance protedure Q0-1, Safety Injection System, the ~perator.
- inadvertently depressed the white light/pushbutton resulting in containment spray pump P-548 starting.
' The cause of the event was an inadequate procedure.
The licensee determined that the standby design feature was not required in the system and should be disabled. A modification has been proposed to permanently disable the containment high pressure push button but r~tain the stand-by indication for the white light. The inspectors will continue td monitor the licensee's activities. This LER is open.
5)
{Closed) LER 255/94011: Previously Unanalyzed Combination of Events Indicates Potential For Inability of a Single Source to Reliably Start Diesel Generators:
On April 25, 1994, an issue was identified where the ability of the emergency diesel generators (EDGs) to start withi~ the prescribed time frame could be adversely impacted when only one starting circuit was available. This would occur with a single failure of a station battery along with a design basis accident and loss of offsite power when the EOG would be relying on the "A" air start circuit. The starting time for
- the "A" air *start circuit had previously exceeded the prescribed start time.
The single failure of a battery had not occurred..
This issue was ~iscussed in the Diagnostic Evaluation Team report, paragraph 2.3.1.1(3), and inspection report 255/94014 in paragraph 2.3.l;l.c. The licensee revised*
Surveillance Procedure No. M0-7A-l, "Emergency Diesel Generator 1-1 (K-6A)" and No. M0-7A-2, "Emergency Diesel Generator 1-2 (K-68)," to declare the EOG inoperable if the elapsed time for the "A" air start circuit was greater than.
9.5 seconds. These changes met the *criteria e~tablished in a letter from the licensee to the NRC dated June l, 1994. * A modification to change the air start motor actuation circuits is discussed as Inspection Followup Item 50-255/94014-42. This LER is closed.
One noncited violati-0n was identified.
No devi~tions, unresolved, or inspection followup items were identified in this area.
5.
Maintenance/Surveillance (62703 and 61726)
a.
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 specifications.
The follo~ing items were also considered during this revi~w:
LCOs were met while components or systems were removed from service; approvals were obtained prior to initiating the work; 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 personnel.
Portions of the following maintenance Work Orders (WO) were observed or reviewed:
WO 24414746:
Repair east engineering safeguards room air compressor, C-6A.
- WO 2441441:
Provide temporary power to the west engine~ring safeguards room
WO 24415078: Adjust air regulator and proportional band for auxiliary feedwater pump P-88 steam driver PC-0521A The inspectors reviewed the followin~ problems that occurred during activities on WO 24414746 on C-6A:
C-6A was originally removed from service to perform scheduled preventive maintenance.
C-6A overheated and failed shortly after being returned to service following completion of the maintenance.
The probable ca~se was a*
maintenance error.
The licensee found that maintenance.
personnel may hav~ incorrectly installed a valve plate on the low pressure suction valve.
- The licensee decided to replace the compressor as a corrective measure after C-6A bverheated and failed. A new compressor was ordered since one was not available in the stockroom.
The new compressor arrived with a 2-belt sheave.
The original had a 3-belt sheave.
To maintain proper
alignment and balance between the new compressor and original motor~ the licensee changed the motor sheave to accommodate the new compressor. This necessitated an unanticipated design change and revealed a lack of attention
- to detail. *
The new compressor was received and transported to the east engineering safeguards room before the.licensee discovered the problem with the sheaves. This reflecting on a weak receipt inspect ion.
- *
After movin~ the new compressor to the east safeguards room,
- the licensee discovered that the oil in the new compressor had not been approved to be taken into the auxiliary building.
The new compressor had been fi)led with shipping
oil, and no Material Safety Data Sheet existed onsite for the shipping oil. Maintenance crews drained the shipping oil and fi 11 ed the compressor with approved oil.
The licensee issued a condition report to evaluate.the maintenance problems encountered.with C-6A.
The inspector noted a positive observation i~ quality of participation of maintenance first line supervisors with field activities. Three maintenance supervisors were present observing workers disa~semble C-6A, when C-6A. *
overheated and failed.
During the review of activities associated with WO 24415078, the inspector observed ari instance of inadequate communication between the two control room operators during the post maintenance testing. The test required operators to establish auxiliary feedwater flow of approximately 150 gpm to each steam generator by opening CV-0727 and CV-0749 using test key TL-2.
Valve CV-0727.
controls auxiliary feedwater flow to steam generator 118.
Valve cv.:..0749 contro 1 s auxiliary feedwater fl ow to steam generator 11A.
The operator reading from the auxiliary feedwater operating procedure SOP-12, instructed the other ~ontrol room operator to
"turn the key," but did not specify which of several keys to ciperate.
The control roo~ supeivisor appro~riat~ly couns~ll~d-the operators on the use of precise communications~ The test was.
~~rformed satisfactorily.
b.
Surveillance Activities (61726)
During the inspection period, the inspectors observed technical specification required surveillance testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that results conformed with technical specifications a_nd procedure requirements and were reviewed, and that any deficiencies identified during the testing were properly resolved.
- The. i~sp~ctors witnessed or reviewed portions of the following.
survei 11 ances:.
RI-958, "Auxiliary Feedwater Flow FT-0749 Instrumentation Loop Calibration," Rev.I.
- Ml-SA, "Containment High Pressure Test, 11 Rev.a. *
Ml-39, "Auxiliary Feedwater Actuation System Logic Test,
Rev.3 No violations, deviations, unresolved, or inspection followup items were identified in this area.
6.
Enciineerinq and Technical Support {83750, 37700, 92720)
The inspector mtinitored engineerin~ and technical suppo~t activities at the site including any support from the corporate office. The purpose
~as to a~sess the adequacy of these functions in contributing properly *
to other functions sue~ as operations, maintenance, ~esting, training~
fire protection, ~nd configuration management.
An NRC regional specialist reviewed the licensee's engineering analyses.
of weld flaws previously identified in Multi-Assembly Sealed Basket No. 4.
The structural evaluation demonstrated adequate design margin and flaw stability. A ~inimum required wall thickness calculation, utilizing a load combination of weight, pressure, and load handling was performed.
This calculation resulted in a minimum required wall of
.31", thus demonst~ating the substantial margin of the existing l" wall thickness.
For purposes of evaluati~g flaw propagation and stability, a bounding analysis was performed on a l" long, throughwall flaw.
This approach was conservative in that the actual flaw of concern was characterized as a.75" long, less than.187" deep, imbedded flaw.
The linear elastic fracture mechanics evaluation resulted in a calculated stress ihtensity factor of 1.3.. Thfs demonstrates. a* factor of safety of It.when c*ompared to the ASME Sectibn XI, IWB 3612 allowable stress intensity of 15.8~
The actual calculated margih against failure was substantially higher.
For the flaw growth analysis, a hoop stress of 1200.psi was applied for 20,000 cycles, resulting in virtually nci growth..The evaluation of the MSB No. 4 flaws was found to be conservative in every respect, and demonstrated substantial margin against failure.
No violations, deviations, unresolved, or inspection followup items were identified in this area.. *
7. *
Tempdrary Instruction (Tl) 2515/125 ~ Foreign Material Exclusion Controls During this inspection, the inspectors conducted a detailed review of the licensee's foreign material exclusion {FME) program per the guidance provided in NRC Inspection Manual Temporary Instruction 2515/125.
This review was accomplished through a combination of procedure and event reviews, discussions with licensee personnel, and observations of activities.
a.
Procedures The fo 11 owing procedures were reviewed by the inspectors:
Procedure No. MSM-M-20, Maintenance Cleanliness Guidelines Procedure No. MSM-M-47, Foreign Material Exclusion in the Spent Fuel Pool Area and Reactor Cavity
Administrative Procedure No. I.OJ, Mat~rial Condition Standards and Housekeeping Responsibilities
Administrative Procedure No. 1.05,, Fuel Integrity Program
Debris Control Plan During Refueling Outages
. *
Containment Management Pl an 1993 Refue 1 i ng Outage
.
.
.
The inspectors noted that the above listed proc~dures confain provisions, as applicable, for material, parts, and tool accountability to ensure that loose items are not inadvertently left inside structures, systems, or components after the work activity is complete.
The subject procedures collectively address FME controls across the various work locations and types of work activities in the plant.
The purpose of the procedures was to protect the reactor and associated systems from fuel failures and other harmful affects **
that could result from foreign material intrusions. The scope of the protedures was to delineate the requirements for housekeeping and foreign material control practices for the foreign material exclusfon._(FME) zon*es at the.plant and to specify actiO-ns to****.
. correct deficient housekeeping practices and/or conditions in a
- timely manner. An FME.zone is a zone Qr area established to prevent the intrusion of unwanted material into the reactor or spent fuel pool (SFP). *
Proced~re MSM-M-20 provides cleanliness guidelines for preventing
- the in.troduction of foreign material into open plant systems and components when specific_requirements were not provided in another
- working level document, during maintenance activities.by any work group. *Guidance was provided for system cleanliness during routine maintenance and modifications, during welding and valve grinding, and for inspection and system c 1 osure fo 11 owing these *
activities..
Procedure MSM-M-47 prescribes requirements for preventing the introduction of for.ei gn material into the reactor core through the.
use of specific work practices in the areas of the reactor cavity *
and the spent fuel pool during the performance of maintenance,
modifications, test, inspection activities, or routine operation.
Work activities performed in the debris free zone (DFZ) were monitored bya debris control monitor (DCM).
The DCM responsibilities include maintaining a Material Control Log and ensuring all aC:tivities in the DFZ were-conducted in accordan~e
- *with this procedure.
. Administrative Procedure I.OJ establishes the overall material condition standards and hbusekeeping responsibilities for work activities at the plant.
b.
Administrative Procedure 1.05 defines the responsibilities and expectations that were integral for developing and implementing coordinated action plans for improving fuel integrity. *Some key*
elements of.the procedure included maintaining debris logs and non-debris logs for the primary containment systems.
The procedure also provides oversight for debris removal in those
- areas and. systems where debris poses a threat to fuel integri_ty.
The licensee has also develope.9 and implemented a refresher training program for debris control/foreign material-exclusion practices at the plant. During the 1993 refueling outage, the licensee implemented a containment management plan to describe the duty positions and responsibilities of the Containment Management _
Team.
Experience and Observations The inspectors reviewed the licensee's internal reporting systems and inspection reports to determine the effectiveness of corrective actions to FME events. There have been several FME events identified by the NRC and the licensee in 1994.
Due to these events occurring in 1994, to verify the effectiveness of _the corrective actions to*these events would be premature. The*
following is.a summary of these 1994 FME events:*
Duririg a NRC Diagnostic Evaluation Team inspection in March-April, 1994, the team identified an excessive amount of material still inside containment that had been left there after closeout following the 1993 refueling outage.
Subsequent inspection of the containment by the licensee identified that signs, adhesive labels, and tape had the potential to block the c~ntainment sump.
This issue is discussed in Licensee Event Report 94-014.
- Also, an inspection follow up item {50-255/94008-01 was idehtified that the FME program for performing containment closeout was not fully effective.
- Inspection Report 50-255/94011 discusses an event wh~re seven water shield. barrels were in containment at the 590 foot elevation in front of the reactor cavity manway flange for several years. These barrels were installed without a safety evaluation.
The concern was that the barrels had the potential of blocking the containment sump during a design basis ace i dent.
No violations~ deviations, ~nresolved, or inspection followup items were identified in this area.
. *.
8.
Report Review During the inspection period, the inspectors reviewed the licensee's monthly operating report for October 1994.
The inspectors confirmed
- that the information provided met the reporting requirements of TS 6.9.1.C and Regulatory Guide 1.1~, "Reporting of Operating information."
No violations, deviations, unresolved, or inspection followup items were.
identified in this area.
- 9.
Meetings and Other Activities (30703)
a.
An enforcement conference was held with the licensee on November 1,.. 1994.
The purpose of the conference was to discuss the recent events concerning the emergency diesel generator's ability to carry peak.design basis. accident loading. See NRC inspection
~eports 50-255/94017 and 50-255/94020 for additional details.
b.
On November 10, 1994, NRC ~onducted a public meeting in Region III to discuss Dry Cask Storage at Palisades. The meeting was held specifically to discuss Sierra Nuclea~ Corporation's and the licensee's actions with regard to quality assurance ~eficiencies
~*~ith cask fabrication.
. c.
On.November 21, 1994, a public meeting was held at White Flint,
. Maryland to discuss pressurized thermal shock issues regarding Palisades'.
The meeting was attended by James M. Taylor, NRC Executive Director for Operations, and William T. Russell, Di~ector of the Office of N~clear Reactor Regulation.
Consumers.
Power Company staff, led by David Joos~ Senior Vice President of Nuclear Operations, and Robert Fenech, Vice President of Nuclear Operations, presented the results cif engineering analysis EA-RDS-94902, Revision 2.
This analysis, submitted to the NRC by letter dated November 18, 1994, showed, that for the conservative neutron fluence values used, the plant could operate until January 1999 before. reaching the screening criteria of 10 CFR 61.
The licensee's staff also outlined interim actions that might be taken to better define and extend the operating time.
- 10.
Exit Interview The inspeitors met with the licensee representatives denoted in
.
paragraph 1 during the inspection period and at the conclusion of the-inspection on December 2, 1994.
The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the informatiori and did not indicate that any of the iriformation disclosed during the inspection could be considered proprietary in nature.
- .
Consumers Power Company ATTN:
T.
Pal~isano General Manager December 14, 1994 Palisades Nuclear Generating Plant*
27780 Blue Star Memorial Highway Covert, MI 49043-9530
Dear Mr. Palmisano:
. SUBJECT:
NRC INSPECTION REPORT NO. 50-255/94018(DRP)
This refers to the routine safety inspection conducted by Messrs. M. E.
. Parker, D.
G~ Passehl, and others of this office, from October 13 through December 2, 1994.
The inspection included a review of* activities at your Palisades Nuclear Generating Facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed report.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, interviews with personnel, and observation of activities in progress. The purpose of the inspection was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements.
- Based on the results of this inspection, certain of your activities, involving access to the plant protected area by an unauthorized individual, appeared to be.in violation of NRC requirements.
However, because the violation met the criteria of 10 CFR 2, Appendix C, Section VII~B(2), the violation will not be cited. There was a concern ide~tified with the timely assessments of oil samples for the auxiliary feedwater pumps that were found in the cri ti ca 1 range.
Increased management attention in the oil sampling program is *
warranted since there have been previous ccince~ns identified in this area.
. In accordance with 10- CFR 2.790 of the Conunission's regulations, a copy of.*
this letter and the enclosed inspection report will be placed in the NRC Public Document Room.
- .
Consumers Power Company
We will gladly discuss any questions you have concerning this inspection.
Sincerely, Ori gin a 1 signed by I. N. Jackiw, Project Engineer for W. J. Kropp~ Chief
.
Reactor Projects Section 2A Docket No~ 50-255 License No. DPR-20.
Enclosure:
Inspection Report
No. 50-255/94018{DRP)
Robett A. Fenech, Vi~e President,
Nuclear Operations
Kurt M. Haas, Safety
~and Licensing Director
James R. Padgett>> Michigan Public
Service Commission
Michigan Department of
Public Health
Department of Attorney Genera 1. {Ml)
Distribution:
Docket File w/encl
PUBLIC IE-01 w/encl
OC/LFDCB w/encl
- SRI, Palisades, Big Rock w/encl
Project Manager, NRR w/encl
PRP w/encl
RII I PRR w/encl
G. E, Grant, RIII.~/encl
Document:
R:\\insprpts\\powers\\pali\\pal94018.drp
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OFFICE
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NAME
Shafer
DATE
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