IR 05000255/1996005

Insp Rept 50-255/96-05 on 960427-0614.No Violations Noted. Concerns Expressed W/Issues Relating to safety-related Sys Operability.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML18065A841
Person / Time
Site:	Palisades
Issue date:	07/30/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18065A840	List: IR 05000255/1996005 ML18065A838
References
50-255-96-05, 50-255-96-5, NUDOCS 9608090222
Download: ML18065A841 (22)

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• Inspectors:

Approved by:

9608090222 960730 PDR ADOCK 05000255 G

PDR U.S. NUCLEAR REGULATORY COMMISSION REGION I I I 50-255 DPR-20 50-255/96005(DRP)

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 April 27 through June 14, 1996 M. Parker, Senior Resident Inspector P. Prescott, Resident Inspector A. Dunlop, Reactor Safety Inspector N. Jackiw, Reactor Projects Inspector J. Lennartz, Reactor Safety Inspector C. Osterholtz, Reactor Safety Inspector T. Polich, Acting Chief Reactor Projects Branch 3

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EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/96005 This integrated inspection included aspects of licensee operations, maintenance, engineering and plant support. The report covers a 7-week period of resident inspection; in addition, it includes the results of announced inspections by regional reactor safety inspectors and a regional projects inspecto Operations

Operations performance for the inspection period was professional and safety conscious (Section 01.1).

• The licensee took conservative actions to restore a fuel assembly that became stuck in the fuel storage rack during fuel movement In addition, troubleshooting and corrective action activities were observed and the inspectors concluded that the licensee conducted these activities in accordance with procedures and approved plant practices (Section 01.2).

• During the licensee's review of industry operating experience, system engineering identified a potential generic concern with cross-connecting the SITs via a non-safety related system. Although the licensee's invnediate action was timely, the inspectors expressed concern with past operability and reportability determinations, based on reliance on a non-safety system to maintain system integrity (Section 01.3).

• The operators responded promptly and effectively to the ground fault on inverter Bus Y-10, and ensured timely restoration of the atmospheric steam dump and bypass valves. Although these valves are not addressed in Technical Specifications (TS), credit is taken for their action in emergency operating procedures. Licensee management provided the appropriate attention and oversight to ensure timely restoration of these valves (Section 04).

• During May 1 and 2, 1996, the inspectors performed a requalification examination for two crew's dynamic simulator examination and sampled Job

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Performance Measures (JPMs) for seven operators. The inspectors concluded the crews' and individual operators' performance was satisfactory; however, a few weaknesses were noted (Section 05).

Maintenance

The licensee~s actions Y'.egarding preparations for and execution of the two maintenance limiting condition for operation (LCO) outages observed were acceptabl The outages generally had more work scheduled, making the outages more challenging and productiv The inspectors confirmed

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that for the observed activities, the licensee left the work areas in a restored and clean condition. The relatively new practice of having technicians walkdown a job prior to actually performing the task was seen as positive. However, as in inspection report 50-255/96003, parts for certain jobs were available only right before the maintenance outage occurred, or not at all, resulting in rescheduling of some work activities {Section Ml.2).

• Based on results of the VOTES test data, review of previous test data from April 1995, and dial indicator measurements, the stem for MOV-3189

{low pressure safety injection pump suction valve) was determined not to be degrade The inspectors viewed the licensee's actions and conclusions as conservative and appropriate {Section Ml.3).

Engineering

The inspectors performed a followup to a licensee review of the design basis document {DBD) for the control room heating ventilation and air conditioning syste The inspectors concluded that the licensee's invnediate compensatory measures were adequat However, the licensee had failed to identify several issues during the 080 review indicating that the licensee review was incomplet The inspectors viewed plans to incorporate changes to the procedures and emergency planning as appropriate {Section E3.l).

Plant Syoport

The inspectors observed that radiological practices for the maintenance outages and daily plant walkdowns were adequate (Section Rl.l).

• Report Details Summarv of Plant Status The unit operated at approximately 100 percent power for the inspection perio Conduct of Operations 01.1 General Comments C71707l I. Operations Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operation In general, the conduct of operations was professional and safety-conscious; specific events and noteworthy observations are detailed in the sections belo.2 Styck Fuel Assembly a. Inspection Scope C71707l On April 19, 1996, operations management notified the inspectors that during fuel movements, the spent fuel handling machine {SFHM) grapple attempted to rotate to the open position while lowering a fuel assembly

{FA) back into its storage location. The inspectors observed licensee actions to restore the fuel assembly to the proper storage position and troubleshooting activitie b. Observations and Findings Spent fuel assembly {FA) inspection was conducted to verify FA condition prior to storage in a dry fuel storage cask scheduled for 199 During fuel movements, which involved lifting the FA in order to visually examine the assembly, the SFHM grapple attempted to rotate to the open position during lowering of the assembly back into its storage rack location. Grapple rotation was stopped in mid-position when it contacted the walls of the spent fuel rac The mechanical interlock on the grapple prevented the FA from coming off the grapple. Rotation of the assembly was noticed by personnel operating the-SFHM and downward travel was immediately stoppe The inspectors viewed by video that the grapple had rotated approximately half-way to the open {ungrappled) position when the SFHM alarm illuminated, indicating that the grapple was not fully closed. The grapple open/close switch was in the closed positio The inspectors observed and assessed operations and engineering

.. _man_ag~!!l~nt'~- d~~hion-making proces Fuel movements were immediately suspended and operations and reactor engineering management were notifie To ensure the grapple could not move and to allow safe insertion of the FA, a temporary procedure change was processed to allow isolation of air to the grapple. All further fuel movement activities

were stopped until a root cause analysis, corrective actions, and management review board *approvals were complete The licensee initiated a condition report, interviewed personnel involved, and contacted the responsible system engineers and the SFHH vendo The initial investigation concluded that the grapple open/close switch had failed, causing the grapple to attempt to disengage. Troubleshooting activities revealed the switch failur An additional concern from this event was that the current software allowed the grapple to be activated independent of load cell weigh One proposed corrective action was to pursue the addition of an interlock into the software to prevent grapple actuation whenever a fuel assembly is supported by the SFH A software change was initiated and would be tested prior to any fuel movement c. Conclusions Based on the licensee's actions to restore the FA to the spent fuel storage rack, the inspectors concluded that licensee personnel and management acted conservativel In addition, troubleshooting and corrective action activities were observed and the inspectors concluded that the licensee conducted these activities in accordance with procedures and approved plant practice.3 Cross-connected Safetv Injection Tanks CSITsl a. Inspection Scope (71707)

During a review of industry operating experience, system engineering identified a potential generic concern with cross-connecting the SIT The licensee initiated a condition report, C-PAL-96-0518, to document this condition and informed the inspectors of their action. The inspectors observed licensee actions to address this concern including reportability, immediate action to prohibit cross-connection, and past operabilit b. Observatjons and Findings System engineering determined that on occasion the operating crew had opened the nitrogen supply valves on two SITs simultaneously in order to equalize system pressur Initial review determined that the practice of cross-connecting SITs was not appropriat Immediate action consisted of prohibiting further cross-connection of tanks. Additionally, the nitrogen supply valves were caution tagged to prohibit simultaneously opening more than one nitrogen supply valv A-con<:fition~report C-PAL-96-0518 was initiated to determine the impact of such action on the ability of the SITs to perform their design functio *

Although the system operating procedure (SOP-3) does not specifically address this practice, the licensee has requested a procedure change to prohibit this practic The licensee's review determined that this condition was not reportable under 10 CFR 50.72 or 10 CFR 50.73. This was based upon a review, which determined that the cross-connection was not outside the design basis requirement Technical Specification 3.3.1.b requires that all four safety injection tanks have a tank liquid level of at least 174 inches and be pressurized to at least 200 psig to be considered operable. Technical Specification 3.3.2.a further states that one safety injection tank may be inoperable for a period of no more than one hou Based upon discussions with licensee personnel, the inspectors determined that the practice of cross-connecting SITs was performed during monthly sampling to maintain or equalize system operating pressures. During the monthly sampling activity, the licensee enters a one-hour limiting condition for operation (LCO) for the tank being sampled, until it is restored to service with appropriate liquid level and nitrogen pressur The inspectors concluded that the practice of cross-connecting SITs during sampling resulted in a degraded condition due to reliance on a non-safety related portion of the nitrogen supply system to maintain integrity during a postulated accident scenario. While the licensee does consider the sampled tank to be inoperable, the adjacent cross-connected tank is also impaired by this practice. Technical Specifications (TS) do not allow more than one of the four tanks to be declared inoperable at one tim The licensee's analysis of the condition determined that the impact to the two cross-connected tanks would result in a decrease in system pressure to 192 psig and would, therefore, have minimal impact on the design basis. This review assumed a loss of one tank through a large break loss of coolant accident (LOCA) and a resultant system decrease to the other connected tan However, the analysis did not consider the failure of non-safety related nitrogen supply piping, which cross-connected the tank c. Conclusions The licensee's identification of this issue was timel The licensee had taken prompt action to prohibit further cross-connection of SITs, even prior to the issuance of NRC Information Notice 96-3 The inspectors concluded that the practice of cross-connection of the SITs using a non-safety related portion of the nitrogen supply system was inappropriat Although the licensee's immediate action was timely, the inspectors expressed concern with past operability and reportability determinations, based on reliance on a non-safety system to maintain system integrit The inspectors plan to monitor the licensee's evaluation of this matte '

• 01.4 Ground Faylt On Preferred AC Bys Y-10 a. Insoectjon Scooe C71707)

On June 2, 1996, operations management informed the inspectors that a ground fault was detected on preferred AC Bus Y-1 The ground fault was initially determined to be caused by failure of HIC-0780A, flow controller to the atmospheric steam dump valve The inspectors witnessed the operator's actions to clear the ground fault and restore the controller to servic b. Observations and Fjndinqs During a review of logs and discussions with plant personnel, the inspectors determined that upon receiving the "Preferred AC Bus Number 1 Trouble" alarm on panel EK 05-43, the control room operators took immediate action per the alarm response procedure for window 43 and Off Normal Procedure 24.1. Operator action consisted of bypassing Channel

"A" of the reactor protection system and entering a seven day LC During panel walkdowns in the control room, control operators observed that the auto light on HIC-0780A was not illuminated. HIC-0780A was powered from preferred bus Y-1 Further walkdowns identified that HIC-07808 and HIC-0781B were illuminated at remote shut down panel, C-3 HIC-0780B and HIC-0781B are the remote controllers for the atmospheric steam dump valve Further troubleshooting by plant electricians-and instrumentation and control (l&C) technicians identified that a negative ground was present on Y-10 DC inputs and that controller HIC-0780A had failed. The ground appeared to be caused by a negative ground on pressure switch PS-0550, and a power supply to several components including pressure transmitter PT-550 to bypass valve flow controller PIC-051 The operating shift recognized, upon detection of the failed HIC-0780A controller, that operation of the atmospheric steam dump valves was not available. Appropriate actions were taken to assure that remote control of the atmospheric steam dump valves was available at remote shutdown panel C-3 In addition, automatic quick open of the turbine bypass valves was not available during trouble shooting with PT-0510 isolated from PS-055 The inspectors observed that operations worked closely with I&C technicians, to ensure that controller HIC-0780A was restored to service in a timely manne The HIC-0780A internal power supply was replaced and the controller was restored to service. However, prior to putting the controller back in service, a detailed testing plan was developed and approved by plant management. Additional licensed auxiliary operators-were-assigned -to -each shift to ensure immediate control of the atmospheric steam dumps at the remote panel, until the controller was fully returned to servic *

c. Conclusions The operators responded promptly and effectively to the ground fault on inverter Bus Y-10, and ensured timely restoration of the atmospheric steam dump and bypass valves. Although these valves are not addressed in TS, nor are they considered safely-related, credit is taken for their action in emergency operating procedure The inspectors concluded that plant management also provided the appropriate attention and oversight to ensure timely restoration of these valve Operational Status of Facilities and Equipment 02.1 Engineered Safety feature System Walkdowns C71707l The inspectors used Inspection Procedure 71707 to walk down accessible portions of the following ESE systems:

Component Cooling Water Room

West Safeguards Room

East Safeguards Room

Both Trains of Control Room HVAC Equipment operability, material condition, and housekeeping were acceptable in all case The inspectors identified no substantive concerns as a result of these walkdown Operator Knowledge and Performance 04.1 Licensed Ooerator Evaluations (71001)

During May 1 and 2, 1996, the inspectors observed and evaluated operator performance during requalification examination administration for two crews' dynamic simulator examination and a sample of job performance measures (JPMs) for seven operators. The inspectors also evaluated the written examination administered to five operators and concluded that the crews' and individual operators' performance was satisfactor Operator Training and Qualification 05.1 Licensed Ooerator Regualification Program Review

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a. Inspection Scope (71001)

The inspectors observed the administration of licensed operator requalification examinations from May 1 through 3, 1996, and reviewed examination materials, records, and procedures pertaining to the licensed operator continuing training progra.* *

• • b. Observations and Findings The licensee had increased the JPM evaluation performance standard in accordance with their recently implemented "zero tolerance" progra Any action that was procedurally directed, including an action that simply verified an expected status or parameter, was considered "critical" and must be completed to receive a satisfactory evaluatio The licensee's program as described in procedure AP 4.05, Revision 11, section 5.2, "Licensed Operator Performance Evaluations," did not require an evaluation of the Shift Supervisor's (SS) ability to manipulate the Emergency Operating Procedures (EOPs).

This could result in an unidentified decrease in the SS's skills regarding EOP implementatio The inspectors reviewed the written examination and identified multiple questions with more than one correct answer as well as examples of direct look up questions. Additionally, some questions were structured such that the correct answer could be identified without the use of references or any system or operational knowledg Questions of this type are considered inappropriate for open reference examination However, the licensee took prompt actions to correct the identified deficiencies prior to examination administratio The facility evaluators demonstrated inconsistencies during operator performance evaluations. For example, one crew was downgraded for classifying dynamic simulator scenario SPE-21 as a Site Area Emergency instead of a more conservative General Area Emergency while the other

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crew was not. Additionally, inspector interviews with licensed operators indicated that operators were held to different standards, dependent on which facility evaluator was used, during performance evaluation Conclusions The inspectors concluded that the licensee's continuing training program was satisfactory. The performance standards for JPM evaluations were considered a strength. The inspectors identified three weaknesses: not evaluating the SS's ability to manipulate EOPs, the developed written examination, and operator performance evaluation inconsistencie Quality Assurance in Operations 07.1 Licensee Se1f-Assessment Activities {40500}

During the inspection period, the inspectors reviewed multiple licensee self-assessment activities, including:

Two Corrective Action Review Board*(CARB) meetings;

Several daily Plant Operations/Maintenance Alignment meetings;

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-* Two -Engfneeri ng Department Standdown Meetings;

Several daily Operations Turnover meetings; and

0.2 The inspectors observed that Palisades management was present and an active participant at the above listed meeting The inspectors concluded that the self-assessment activities observed were effectiv Miscellaneous Operations Issues (92700 and 92901)

CClosedl Violation 50-255/94013-03: Technical error in EOP 9.0,

"Functional Recovery Procedure,* prevented the procedure intent from being accomplished. Step l.d of EOP 9.0, "Continuing Actions for PCS/Core Heat Removal," incorrectly directed operators to close valve MV-CD139 when instead it should have directed valve MV-CD138 close The inspectors reviewed the EOP and concluded the procedure step has been appropriately revised. This item is close Followyp on weaknesses identified in report 50-255/95006CDRSl: The inspectors reviewed the following weaknesses identified during the licensed operator requalification program inspection conducted March 27 through 31, 1995:

The control and revision of JPM *

The absence of low power or shutdown scenarios and time critical JPMs in the evaluation ban *

Documentation of individual operator performance during dynamic simulator evaluation *

Training personnel qualification card completion and the auditing of evaluator *

Absence of approval cover sheets for simulator performance evaluation scenario The inspectors concluded the licensee had taken appropriate actions to adequately address the above weaknesse II. Maintenance Ml Conduct of Maintenance Ml.1 General Comments a. Inspection Scope {62703 and 61726)

The inspectors observed all or portions of the following work activities:

• * *

24412680:

24513998:

0319EDA03:

24611247:

J Replace Viking switches on EOG 1-2 FO belly tank with new type per FES94-141 Install new compressor for EOG 1-2 per FES95-239 Relocate conduit and reterminate CRHVAC humidifier Adjust stroke of CV-1656 service_water control valve for CRHVAC condenser

• *

24612283.2:

24610511.3:

24611245:

Replacement of P-55A charging pump suction accumulator bladder P-55A charging pump fluid drive oil change P-54A containment spray pump DP indicator isolation valve MV-ES3414, open and inspect Surveillance Activities

PPAC EPS107:

Calibration of the jacket water, lube oil and fuel oil temperature switches, indicators and controls, and verify alarms

Special test of CRHVAC in emergency mode to prove the viewing gallery and technical support center (TSC} could be maintained at a positive pressure

Special post maintenance testing of HIC-0780A, atmospheric steam dump flow controller b. Observations and Findings See the specific discussions of maintenance observed under Ml.2 and Ml.3, belo Ml.2 Execution of Maintenance Limiting Condition for Operation Outages a. Inspection Scope {62703}

The inspectors observed several planned maintenance limiting condition of operation outage The inspectors observed work in the field and attended planning meeting The LCOs observed were for the EOG 1-2, the B train of CRHVAC, P-54A containment spray pump, P-678 LPSI pump and P-55A charging pum b. Observations and Findings In inspection report 50-255/96003, a maintenance LCO for the EOG 1-1 was observe Weaknesses were noted in planning and pre-staging for work activities. The maintenance department critiqued the jobs and identified most deficiencies. While minor weaknesses were observed in several maintenance outages during this inspection period; management efforts to resolve issues were eviden More work was scheduled for the EOG 1-2 LCO than in the previous EOG 1-1 maintenance outag One problem noted with the EOG 1-2 outage was the late arrival of the new type of level switches for the fuel oil belly tan For the pre-job walkdown, the mechanical maintenance technicians had to estimate clearances for the vent piping and switches around the fuel oil tank support The licensee determined to proceed with this work for the EOG 1-2 LC Installation encountered only minor problem Work was also planned for the CRHVAC condensing unit instrument, annubar FE-0891, which was encompassed by the service water (SW) tagout required for the EOG 1-2 coolers. However, the licensee had to stop work because of an inadequate drain path specified in the tagout for the SW syste The B train CRHVAC work encountered a minor problem of no vendor drawing for the condensing unit control valve, CV-165 The valve leaked by when the unit was shutdown, due to the valve not fully stroking, and the handwheel was sticking. Eventually, the valve was repaired without reliance on the vendor diagram Troubleshooting was performed on MV-ES3414, isolation valve to the P-54A containment spray pump DP gaug The stem of the valve was found to be galled. Since no spare valve was on hand, the valve was reassembled and returned to service. The licensee planned to replace the valve as soon as a new valve is procure c. Conclusions The licensee's actions regarding preparations for and execution of maintenance LCO outages were acceptabl The outages generally had more work scheduled, making the outages more challenging and productiv The inspectors confirmed that for the observed activities, the licensee left the work areas in a restored and clean conditio The relatively new practice of having technicians walkdown a job prior to actually performing the task was seen as positive. However, as in the previous inspection report 50-255/96003, parts for certain jobs were available only right before the maintenance outage occurred, or not at all, resulting in rescheduling of some work activitie Ml.3 Valve Ooeration Test And Evaluation Svstem CVOTESl Testing of MOV-3189 a. Inspection Scope (62703)

The inspectors observed the diagnostic testing of valve MOV-3189, suction valve from the SIRW, for LPSI Pump P-67 The testing was performed using the VOTES testing equipmen b. Observations and Findings During VOTES diagnostic testing of MOV-3189, LPSI suction valve from the-SIRW tank, the results of the operating performance characteristics (diagnostic testing) prior to the refuel outage in April 1995, indicated a slight degradation of the valve ste The licensee determined that this condition did not render the valve inoperable and the valve was returned to servic On June 11, 1996, the inspectors observed a scheduled test on MOV-3189 to-determine* if-further degradation of the valve stem had occurre The following activities related to this scheduled test were observe..

A detailed pre-job briefing was conducted with personnel involved in the tes *

Hookup and prestaging of measurement and test equipment was performed as require *

Testing was performed in accordance with approved procedure MSE-E-21, "VOTES Diagnostic System Operating Procedure.*

Based on results of the VOTES test data and review of previous test data from April 1995, the licensee concluded that the stem for MOV-3189 was not degrade The inspector independently reviewed the test data and found the licensee's conclusions to be acceptabl The licensee suspected that the anomalies in test data in April 1995, were a result of electrical noise. Additional testing of the valve stem using a dial indicator, confirmed that the valve stem was not bent. During this testing, an NRC inspector was present and acknowledged the licensee's conclusion The licensee will continue an increased surveillance schedule for this valv The licensee also planned to send the valve's VOTES traces to the software vendor for further analysi c. Conclusions Based on results of the VOTES test data, review of previous test data from April 1995, and dial indicator measurements, the stem for MOV-3189 was found not to be degrade The inspectors viewed the licensee's actions and conclusions as conservative and appropriat e III. Enqineerina E3 Conduct of Engineering E3.l System Not Tested To Pesiqn Basis Requirements a. Inspection Scope {37551)

Inspection report 50-255/96003 detailed inspector's findings that 14 system DBDs had not been reviewed or updated in over two year Subsequent to that inspection the licensee performed further review In one review a design engineer found in the DBD for CRHVAC, that the fire door between the two trains of CRHVAC was required to remain open to ensure pressuri_zatjon 9f the out of service train's -mechanical equipment room (MER).

The door is normally closed to satisfy fire protection requirement In response to this licensee finding, the inspectors conducted a review of the final safety analysis report (FSAR} and the DBD to ensure compliance with design basis requirement b. Observations and Findings

--Duringa review-of-DBD 1.06 "CRHVAc,* a design engineer noted that per section 3.2.1.c.5.(c}, door-SIA was required to remain open to ensure pressurization of the out of service train's ME The door is located in

a wall between the two trains of CRHVA This was a change in the original design incorporated by field change FC-50 To allow the door to remain open, a fusible link closer was installed. However, the hold open feature was disabled by disconnecting the spring that provided force to keep the door ope The reason why the hold open feature was defeated and when this occurred was unknow This created the potential for failure to keep both MERs pressurize The MERs are required to be at a positive pressure to prevent inleakage to the CRHVAC envelop The licensee notified the NRC of a condition outside of the design basis that concerned the CRHVAC syste The licensee's immediate compensatory measures were to prop open door-SIA and institute a one hour fire tou The licensee has not yet determined what final corrective actions will be institute Following the licensee's identification of the MER door condition, the inspectors performed an independent review of the FSAR and DBD 1.0 In the FSAR under section 9.9 nHVAC," it stated, "During emergency mode operation, the CRHVAC system maintains a.125"WG of water-positive pressure in the control room, TSC and viewing gallery. The MER is also maintained under positive pressure."

The inspectors reviewed R0-28, "Control Room/TSC Ventilation,n and discussed with the system engineer data gathering techniques used to determine that the requirements of the FSAR were being me The inspectors identified to the licensee that no readings were taken in the TSC and viewing gallery. A normally closed door and walls isolate the control room from the viewing gallery and TS The inspectors also identified to the licensee that section 3.2.11 of DBD 1.06 stated, "The pressurization may dip below o.12snwG when a transient opening occurs in the controlled envelope boundary (opening the outside door in the TSC, for example}.

The inspectors interpreted thi*s to mean that it was acceptable to drop below the limit of 0.125"WG when a door was opened to one of the controlled spaces (control room~ TSC and viewing gallery}; however, pressure may not go negative with a door ope The licensee had not previously verified this conditio The licensee assessed the inspectors' findings and performed testing necessary to verify the TSC and viewing gallery would remain greater than 0.125"WG in the emergency mod With the CRHVAC in emergency mode of operation, the licensee demonstrated that pressure in the TSC and viewing gallery could be maintained above 0.125"W Although pressure did drop below 0.125"WG with both doors opened, pressure in these rooms remained positive. The licensee committed to change to the test procedure to ensure periodic testing is performed. Also, the system engineer has notified the emergency preparedness training department that in case of a radiological event, adequate measures should be put in place to ensure that both doors are not opened simultaneously, thereby dropping room pressur In addition to incorporating these steps in emergency

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training, the licensee is evaluating the placement of signs on control room and TSC doors that both vestibule doors should not be opened at onc c. Conclusions The inspectors concluded that licensee's immediate compensatory measures were adequat However, the licensee had missed several issues during the DBD review indicating that the licensee review was incomplet The inspectors viewed plans to incorporate changes to the procedures and emergency planning as appropriat ES Miscellaneous Engineering Issues (92902 and 92702)

ES.I <Closed) Violation 50-255/95011-01:

Failure to obtain NRC approval prior to implementing a proposed alternative to the ASHE Code vibration acceptance criteria for the inservice testing of the containment spray and low pressure safety injection pump The licensee reviewed the inservice test (IST) program and did not identify any additional relief requests requiring prior NRC approva The licensee resubmitted the proposed relief request on September 18, 199 The NRC issued a safety evaluation dated October 12, 1995, approving the relief request. This item is close EB.2 (Closed)

LER 50-255/94004-01 Engineered safeguards system (ESS) pump cooling single failure. Cooling water to the ESS pumps was normally supplied by SW, but on a safety injection signal, the SW supply and return valves close and the component cooling water (CCW) supply and return valves ope Failure of one of the CCW valves to open would result in loss of ESS pumps seal coolin The licensee addressed the issue by realigning the CCW valves to be normally open and the SW valves to be normally closed, which eliminated the potential single failure. Additional corrective actions identified in the LER ensured the revised valve lineup did not cause other system concerns and no further potential single failure scenarios existed in the SW and CCW systems. This item is close EB.3 <Closed} Unresolved Item 50-255/94002-01:

Lack of over pressure protection for the CCW heat exchanger The licensee at the time of the inspection was unable to ret_ri eve a summary technical report to verify the CCW heat exchanger was adequately protected from an over pressure even Since the licensee was unable to retrieve the original summary technical report, the analysis verified there were no potential normal or transient conditions that could lead to an over pressurization even The analysis included system pressurization from pumps and temperature effects. In addition, the analysis addressed normal and maintenance system lineups that provided assurance that over pressurization would not occu The outlet isolation valves from CCW and the inlet isolation valves from SW were normally locked open manual valves controlled by plant procedure....

Isolation of a heat exchanger was adequately controlled by normal plant procedures to open vent plugs when the inlet and outlet valves were closed. This item is close E8.4 (Closed) Unresolved Item 50-255/94002-02:

Inability to determine if the SW system would fulfill its safety function at elevated lake water

. temperatures combined with other adverse design basis conditions. The other issues included the following:

(1) design calculations did not account for instrument uncertainties, changes to design heat exchanger fouling factors, and SW pump degradation; (2) ensuring the most limiting SW system lineup was tested; (3) the impact of increased SW temperatures and reduced SW flow rates on SW and CCW system operations; and (4)

determining the root cause of reduced flow to the control room chiller Regarding item (1), the licensee prepared engineering analysis EA-D-PAL-93-272£-01 to account for the issues associated with potential system degradation and developed acceptance criteria to be used with the.SW flow balance test, T-216, Rev. 7, "Service Water Flow Verificatio Subsequent performances of T-216 and evaluation indicated the SW system was capable of performing its intended.functio Regarding item (2), the analysis also reviewed SW system lineups and determined that T-216 adequately represented the most limiting hydrau.lic system lineu Regarding item (3), the impact of higher SW temperatures was analyzed and determined not to exceed any SW or CCW system design limits.

Regarding item (4), during the disassembly and inspection of the control room chillers it was identified that the head gaskets were blocking a significant portion of the tube The gaskets were replaced and flow rates measured in subsequent tests increased to acceptable limits; however, the flow rate for chiller VX-11 did not increase as much as expecte Plans during the 1996 refuel outage call for a modification on the long run of horizontal piping that would allow for use of better inspection techniques and cleaning if partial plugging is found in the pip Based on the actions taken or planned, this item is close E8.5 <Closed) Unresolved Item 50-255/94002-0l: Coupling of all Section XI IST pump test acceptance criteria with the safety analysis performance criteria to ensure pump degradation would not affect system operabilit The licensee verified through analyses that all Section XI pumps IST acceptance criteria were adequate to verify system operability. This item is close E8.6 (Closed) LER 50-255/95001: Spurious activation of Left Channel

. Sequence On March*2, 1995, the left thannel sequencer MC-34L, spuriously activated and started left channel equipment. All equipment responded as expecte The design basis accident sequencers, MC-34L and MC-34R, sequence loads onto the EDG Sequencing of loads ensures that

• appropriate equipment is energized in time to contend with an event, while at the same time preventing excessive step loads from being placed on the EDG {which could result in the loss of the generator).

The licensee established a team to determine root cause and evaluate common mode failure By a thorough process of elimination of other components in the logic circuit, the licensee determined the problem was most likely in the micro-processor module of the electronic DBA sequence The micro-processor module was then sent to the vendor to troubleshoot. The micro-processor was first put through a test new modules would receiv No error was foun The module was then placed into an extended test to see if a failure would occur with a longer run time. Again, no errors were foun The vendor concurred with the licensee that the failure was an anomalous event with a low probability of a repeat failure. A year has passed with no similar events. This item is close E8.7 CClosedl Violation EA 94-041. Inspection Report 50-255/94002: This item

concerned five failures to take prompt corrective action when significant conditions adverse to quality were identifie a. The first item concerned the failure to take corrective actions when it was identified that backup cooling to the ESS pumps from the SW system could not be accomplished during a loss of coolant accident coincident with a loss of offsite power because non-safety related air was required for valve actuatio Normal ESS pump cooling was changed from SW to CCW such that the initiating single failure event of one of the two CCW valves not opening {see closure to LER 94-004-01) was remove As such, the need for backup cooling from SW would require the loss of all three CCW pump Since the option of using the backup water source was still available to the operators, caution statements were added to SOP 16, Re, *component Cooling Water,* to inform the operators that the CCW valves {CV-0913 and CV-0950) will not close with a standing safety injection actuation signal in effect and opening the SW valves to initiate backup cooling would drain the CCW system if either the CCW supply or return valve remained ope b. The second item concerned the failure to take corrective actions when it was identified that the non-critical isolation valve, CV-1359, was not included in the leakage test program since leakage through this valve could affect the SW system's capability to perform it's intended function at elevated lake temperature Leak testing of CV-1359 was incorporated into T-216 to verify leak rates on a refueling outage frequenc Leak rates during the 1995 refuel outage were measured to be approximately 2 gpm through the valve, which was well within the bounding value {400 gpm)

used in the analysis to develop SW flow balancing flow rate c. The third item concerned the failure to take corrective actions when it was identifie~that instrument tubing and unistr~t sup~orts located in front of the CCW heat exchanger were bent. Licensee analysis determined that the tubing did not meet FSAR Section 5.7 requirements for allowable stress, although it did meet the plant's operability criteria for

• continued operation. The tubing and unistruts were repaired during the I995 refuel outage to conform with FSAR requirements for allowable stres d. The fourth item concerned the failure to take corrective actions when it was identified that the SW IST pump reference values were not coupled to the SW system flow balance test, which created the potential for SW pump performance to degrade below minimum system flow requirement To address this issue, the licensee performed engineering analysis, EA-D-PAL-93-272E-OI, Rev. 2, "Degraded Service Water System Hydraulic Performance Considering System Degradation." The analysis took into account degraded pump performance, basket strainer fouling, minimum lake level, boundary valve leakage, and instrument inaccuracies. The SWIST and T-2I6 acceptance criteria were based on the analysis result e. The fifth item concerned the failure to take corrective actions when it was identified that SW test T-2I6 balanced flow to the CCW heat exchanger at or very near the required flow rates, which left little or no margin for reduced SW flow that could result from SW pump degradatio As discussed above, the acceptance criteria now established for the flow balancing test included pump degradation and other potential flow inaccuracies to adequately address this issu This item is close However, the evaluation of the effectiveness of the corrective action process is open and w~ll be tracked in open item 255/940I4-73.

Rl IV. Plant Support Radiological Protection and Chemistry.Controls RI.I Maintenance Outages and Daily Radiological Worker Practices a. Inspection Scope {83750)

The inspectors observed radiological worker activities during the various applicable maintenance outages detailed in this inspection report, and also monitored radiological practices during daily plant tour b. Obseryations and Findings During the applicable maintenance outages radiation technicians were visible at the job sites. The technicians took appropriate actions and surveys in accordance with good ALARA practice c. Conclusion The inspectors concluded that radiological practices observed during the maintenance outages and plant daily walkdowns were adequat The inspectors had no concern IS

v. Management Meetings Xl Exit Meeting Sumnary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 14, 1996. A separate exit was held on May 3, 1996, for the licensed operator requalification program evaluation. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietar No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED Licensee R. A. Fenech, Vice President, Nuclear Operations T. J. Palmisano, Plant General Manager K. P. Powers, Nuclear Services General Manager K. A. Toner, Acting Nuclear Performance Assessment Manager H. L. Linsinbigler, Design Engineering Manager R. W. Smedley, Licensing Manager D. W. Rogers, Operations Manager J. P. Pomeranski, Maintenance and Construction Manager D. P. Fadel, System Engineering Manager D. G. Malone, Shift Operations Supervisor D. J. Malone, Chemical & Radiation Protection Services Manager K. M. Haas, Training Manager S. Y. Wawro, Planning & Scheduling Manager M. E. Parker, Senior Resident Inspector, Palisades P. F. Prescott, Resident Inspector, Palisades

INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observation IP 62703: Maintenance Observation IP 71001: Licensed Operator Evaluations IP 71707: Plant Operations IP 83750: Occupational Radiation Exposure IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92701: Followup IP 92702: Followup on Corrective Actions for Violations and Deviations IP 93702: Prompt Onsite Response to Events at Operating Power Reactors IP 92901: Followup-Plant Operation IP 92903: Followup-Engineering ITEMS OPENED AND CLOSED Opened 50-255/96005-01 NCV Requalification program cycle exceeded 24 month requirement of 10 CFR 55.59(a)(l) (Section 05.1).

Closed 50-255/95001 LER Spurious activation of left channel sequencer 50-999/96002-03 IFI Adequacy of safety injection system surveillance test 50-255/94013-03 VIO Technical error in EOP 9.0, RFunctional Recovery Procedure,w prevented the procedure intent from being accomplished 50-255/95011-01 VIO Failure to obtain NRC approval prior to implementing a proposed alternative to the ASHE Code vibration acceptance criteria for the inservice testing of the containment spray and LPSI pumps 50-255/94004-01 LER ESS pump cooling single failure 50-255/94002-01 URI Lack of overpressure protection for the CCW heat exchangers 50-255/94002-03 URI Coupling of all Section XI IST pump test acceptance criteria with the safety analysis performance criteria to ensure pump degradation would not affect system operability EA94-041/94002 VIO The specific examples identified in the violation are closed, however, the violation will remain open pending a review of licensee's over all corrective action process and recent implementation (Section ES.7).

r, AC A LARA CARB CFR CRHVAC CV OBO DC OP ORP EOG EOP ESF ESS FA FO FSAR l&C IFI IR IST JPM LCO LER LPSI MER MOY NCV NRC POR SFHM SIRW SIT SW TS TSC URI VIO VOTES WG LIST OF ACRONYMS USED Alternating Current As Low As Reasonably Achievable Corrective Action review Board Code of Federal Regulations Control Room Heating Ventilation & Air Conditioning Control Valve Design Basis Document Direct Current Differential Pressure Division of Reactor Projects Emergency Diesel Generator Emergency Operating Procedures Engineered Safety Feature Engineered Safeguards System Fuel Assembly Fuel Oil Final Safety Analysis Report Instrumentation and Control Inspection Followup Item

Inspection Report

Inservice Test

Job Performance Measure

Limiting Condition of Operation

Licensee Event Report

Low Pressure Safety Injection

Mechanical Equipment Room

Motor Operated Valve

Non-Cited Violation

Nuclear Regulatory Commission

Public Document Room

Spent Fuel Handling Machine

Safety Injection and Refueling Water

Safety Injection Tank

Service Water

Technical Specification

Technical Support Center

Unresolved Item

Violation

Valve Operation Test Evaluation System

Water Gauge