IR 05000255/1998011

Insp Rept 50-255/98-11 on 980518-0604.No Violations Noted. Major Areas Inspected:Licensee C/As & Engineering Involvement in C/A Process

ML18068A362
Person / Time
Site:	Palisades
Issue date:	07/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18068A361	List: IR 05000255/1998011 ML18068A360
References
50-255-98-11, NUDOCS 9807100342
Download: ML18068A362 (13)

Text

U.S. NUCLEAR REGULATORY COMMISSIO REGION Ill

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Docket No:

50-255 License No:

DPR-20 Report No:

50-255/98011 (DRS)

Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, Ml 49201 Facility:

Palisades Nuclear Generating Plant Location:

27780 Blue Star Memorial Highway Covert, Ml 49043-9530 Dates:

May 18, 1998, through June 4, 1998 Inspectors:

R. Mendez, Reactor Engineer Approved by:

R. N. Gardner, Chief Engineering Specialists Branch 2 9807100342 980702

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POR ADOCK 05000255 G

PDR

• EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report No. 50-255/98011 This inspection reviewed aspects of licensee corrective actions and engineering involvement in the corrective action process. The inspector determined that the licensee was effective in identifying and implementing corrective actionsto notices of violation, inspection follow up item, unresolved items and licensee event reports. In addition, the engineering staff was knowledgeable and involved in the corrective action proces Engineering

Corrective actions and root cause analyses were acceptable (all sections).

• System engineering involvement in the corrective action process was good (all sections).

• The engineering staff was effective in the identification and resolution of technical issues. However, concerns were identified regarding the licensee's review of a non-environmentally qualified cable and the lack of a qualified three-hour fire barrier where redundant safe shutdown circuits were routed in close proximity (Sections E8.15 and E8.16; unresolved item (URI) 50-255/98011-01 and URI 50-255/98011-02, respectively).

• Report Details Ill. Engineering The inspection included a review of the licensee's corrective actions and engineering involvement in the corrective action process. The inspector determined that the licensee was effective in implementing corrective actions to notices of violation, inspection follow up items, unresolved items and licensee event reports. The engineering staff was knowledgeable and involved in the corrective action proces EB Miscellaneous Engineering Issues (37550, 92700 and 92903)

E (Closed) Licensee Event Report No. 50-255/93012-00: The containment high pressure (CHP) and containment high radiation (CHR) relays were not seismically qualified. The licensee determined that the relays had undersized coils and would possibly not operate following a design basis accident. Qualification testing reports had not conclusively demonstrated that these relays would operate during a seismic event when configured with nine or more normally closed contacts. The test reports showed a tendency for the minimum pick-up voltage to increase following a seismic event. According to the licensee's assessment, because of the installed configuration of the CHP and CHR relays, the containment high pressure and containment high radiation systems were not capable of performing their intended safety functions under certain design basis conditions. This resulted in the NRC issuing a Severity Level IV violation for the licensee's failure to adequately control design measures. The violation was

documented in an NRC inspection report under item 50-255/93026-01. The licensee replaced all the relays in the CHP and CHR circuits configuredwith nine or more normally closed contacts. The inspector reviewed the work orders that replaced the coils and the post modification testing performed. Engineering involvement in the resolution of this issue was goo E (Closed) Licensee Event Report No. 93-014: The licensee found that the electrical penetrations in the north and southwest auxiliary building did not meet design features described in Technical Specifications and the final safety analysis report (FSAR). In each room, a non-seismic nitrogen system was connected to each electrical penetration between the double barrier. In addition, the bottles and connecting piping for the nitrogen system were located outside the auxiliary building and, therefore, were not tornado protected as required by the FSAR. The cause of this event was inadequate design control. The design of the electrical penetrations was modified in 1970 and again in 1982 without recognizing all of the design requirements of the electrical penetrations as containment isolation boundaries. As part of the corrective actions, the licensee installed a check valve outside the penetration but still within the auxiliary building. Thi check valve would serve as an isolation valve and was Appendix J tested. This was

• considered acceptabl E (Closed) Violation 50-255/93026-05: A modification was made to a spare safety-related breaker without the required design control measures. The modification to a 2400 volt feeder breaker was performed under a work order instead of the formal design review

E E E E *

process. The licensee determined that the root causes were: (1) a lack of vendor information on the spare breaker internals, (2) the modification process was not used, and (3) the system engineer re-configured the spare breaker to match the vendor manual rather than the configuration required by the plant. The licensee addressed the root causes and as part of the correction actions, the licensee held training for the engineers on the lessons learned. In addition, the licensee developed a procedure, N SPS-E-17, "Temporary Installation and Removal of Spare Circuit Breakers," Revision O, that provided instructions for the temporary installation and removal of spare circuit breaker (Closed) Violation 50-255/93026-01 (93277-01013): The design measures applied to change the engineered safeguards room cooler fan motor thermal overloads were inadequate. The licensee set the trip setpoints at or below the normal operating current without adequate design reviews and without suitable post modification testing to check the adequacy of the design. This problem was found during technical specification surveillance testing with the plant in cold shutdown. However, the reactor had been critical with the safeguards room cooler fans inoperable and, therefore, incapable of performing their design function. The inspector reviewed work orders and post modification testing and found the work implementation and testing was adequate. In addition, a review of design control procedures was determined to be acceptabl (Closed) Violation 50-255/93026-02 (93277-02014): The CHP and CHR relays were determined riot to be seismically qualified. The description and corrective actions for this issue is documented above in licensee event report 50-255/93-012. The licensee's corrective actions were acceptabl * (Closed) Licensee Event Report No. 94-005: The licensee determined that the circuit and raceways schedules showed that instrument cables were routed through a divided tray but plant cable tray layout drawings indicated that a separation barrier was not installed in the cable tray. In an attempt to resolve this issue the licensee performed testing to determine the exact location of the cables. The licensee found that the cables were routed in conduit and consequently, the license withdrew this LER. The inspector verified that drawings were updated to reflect the correct routing of the cable * (Closed) Licensee Event Report No. 94-007: The emergency diesel generator (EOG)

fuel oil supply did not meet licensing basis. During an evaluation of the EOG, the licensee determined that the emergency fuel oil supply system, including the storage tank and associated piping, were not protected against tomados and seiches because the piping was installed above ground. Consequently, the emergency fuel oil supply did not meet 1 O CFR 50, Appendix A, general design Criterion 2. A tornado or a seiche could have caused damage to the fuel transfer system and consequently, the ability to provide diesel fuel to the EDGs. The licensee's interim compensatory measures included providing a manually connected transfer hose to transfer oil from the storage tank to the EOG day tanks. The permanent corrective actions included installing a new storage tank and installing all the new piping below ground. The new storage tanks increased the capacity of fuel oil, at the plant, from 30,000 to 50,000 gallons. The failure to assure that applicable design requirements were met is a violation of 1 O CFR Part 50,

Appendix B, Criterion Ill. The new storage tank and associated piping were protected against tomados and seiches. This non-repetitive licensee identified and corrected violation is being treated as a non-cited violation, consistent with ~ection Vll.8.1 of the NRG Enforcement Policy (50-225/98011-01).

E (Closed) Licensee Event Report No. 94-008: The licensee identified 12 discrepancies where Class 1 E and non-Class 1 E circuits were not isolated or separated as required by the Palisades FSAR. The licensee determined that the causes for the deviations included inadequate design reviews and design installation controls used at t~e time of plant construction or subsequent modifications in the 1980's that added cabling or additional control circuits to the plant. These conditions had existed since original plant construction. The licensee performed immediate corrective actions with the exception of the core exit thermocouples (CETs). The CETs were connected to the non-Class 1 E data logger computer. Therefore, a fault on the data logger computer could have potentially rendered all the thermocouples inoperable. During the inspection, the inspector verified that the drawings were updated to indicate that the thermocouples were not connected to the data logger computer. In addition, the inspector verified in the control room that the thermocouple leads were de-terminated. The failure to assure that design reviews and design controls be established is a violation of 10 CFR Part 50, Appendix B, Criterion Ill..This non-repetitive, licensee identified and corrected violation

• is being treated as a non-cited violation, consistent with Section Vll.B.1 of the NRG Enforcement Policy (50-255/98011-02).

E (Closed) Unresolved Item 50-255/94011-01: The inspectors were concerned that the licensee had modified twelve Class 1 E circuits but had not implemented the required isolation requirements specified in the FSAR (see LER 94008). The licensee had identified that the deviations resulted from inadequate attention to isolation criteria and that inadequate drawings existed at the time the modifications were installe Subsequently, the licensee developed composite schematic drawings for each AC inverter distribution breaker currently in service and tone traced all connections to confirm non-1 E to 1 E isolation. In addition, the licensee updated the design and design interface procedures so that design reviews adequately addressed class IE and non-class IE interfaces. The unresolved item is not cited as a violation because the issue is related to LER 94008 which is treated as a non-cited violatio E8.10 (Closed) Inspection Follow up Item 50-255/94014-27: In June 1993, the inservice inspection (ISi) department was not aware that four motor operator valve (MOV) gear ratios had been modified. The design work and design reviews were appropriately implemented but the ISi department was not aware that new baseline stroke times for the valves were required to be taken. This occurred in part because the base line stroke time tests for these MOVS were similar to the stroke times before the modification Consequently, the ISi department did not become aware of the modification until two of

• the valves were found to be in the alert range in December 1993. -The licensee determined that the design interface procedures and the design process were not being properly implemented. The licensee held training for the technical staff on improving the control and quality of design change wor ES.11 (Closed) Inspection Follow up Item 50-255/94014-28: The DET inspection determined that the licensee did not have a relief valve setpoint document and that the licensee relied on data information that may not have accurately reflected design requirement The licensee had the ability to obtain this information from vendor documents but this

. information was not contained in a single document. Subsequent to the inspection, the licensee reverified the relief valve setpoints. A basis document was developed and was included in Attachment 3 of procedure No. MSM-M-60, "ASME Safety/Relief Valve Testing for Valves Included in ASME Section XI Scope," Revision 2.

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ES.12 (Closed) Inspection Follow up Item 50-255/94014-46: Root cause evaluations for apparent slow starts of the emergency diesel generators (EDGs). During the DET th team noted that the EDGs were meeting the technical specification (TS) start requirements but that the start times appeared slow. Since the DET inspection the.

licensee replaced the air receiver and the air start motors. The air start motor contributed to the slow starts. These motors were to be replaced on a two year preventative maintenance frequency. The inspector noted that the start times for the EDGs improved by 1. 7 seconds since the air start motors were replaced. Engineering involvement and corrective actions to resolve and understand the root cause of the slow starts was goo ES.13 (Closed) Inspection Follow up Item 50-255/94014-55: The DET concluded that the licensee was over-relying on operator actions. The DET inspectors were concerned that operator actions could potent_ially complicate the response to off-normal plant conditions. Three examples were documented in the DET inspection report (94014) and the examples were satisfactorily resolved. In addition, the licensee developed guidance

. in procedures No. 9.01, "Request for Plant Modification," Revision 7, and No. 4.06,"

Emergency Operating Procedure Development and Implementation," Revision 7, to*

minimize over-reliance on operator actions. These procedures outlined guidance for consideration of maintenance or operator resources and human factors engineerin ES.14 (Closed) Inspection Follow up Item 50-255/94014-65: The DET inspection found that the licensee did not properly control vendor manuals and did not ensure that updated vendor bulletins were formally reviewed for site specific applicability. This problem occurred because engineers were assigned the responsibility for reviewing the vendor manuals but there was no method for tracking the review by the engineer. Since the DET inspection, the licensee assigned the Engineer Records Center (ERC) department, the responsibility for receiving, controlling, and tracking vendor manuals. The vendor manuals were now assigned to system engineers who determined the applicability to maintenance procedures and drawings. The instructions for vendor manual control was outlined in procedure No. 9.45, " Vendo.r Manual Control," Revision 3. The inspector noted improvements in vendor manual control since ERC was assigned the responsibilit ES. 15 (Closed) Licensee Event Report 94015: An examination of an electrical cable revealed that the cable was not environmentally qualified (EQ) for use in an application which required qualified cable. The non-EQ cable, routed in containment, provided power to a solenoid valve which, on receipt of a safety injection (SI) signal, would de-energize and

vent the control air used to open a pressure control valve (PCV). The design and safety function of the PCV, located in the outlet piping to one of the four safety injection tanks, was to close on receipt of the SI signal. Under certain conditions grounds in this circuit could keep the solenoid valve energized keeping the PCV open and diverting flow away from safety injection tanks and away from the reactor. The licensee's corrective*

actions included modifying the circuit to reduce the likelihood that the solenoid valve remained energized. The licensee did not change or replace the non-EQ cable with one that was environmentally qualified because of the cost involved and because the licensee determined that the failure of the cable would result in the PCV changing position to the safe or closed condition. This item is unresolved pending additional review of the cable failure m.echanism (50-255/98011:..03), *

E8.16 (Closed) Licensee Event Report 95004: On July 14, 1995, the licensee determined that the 1-2 EOG power and control circuits did not meet 10 CFR 50, Appendix R, Section 111.G requirements. Power and control circuits required for safe shutdown associated with the 1-2 EOG were routed near the intake air plenum of the redundant 1-1 EOG. The air intake plenum area to the 1-1 EOG did not have a qualified three-hour fire barrier separating it from the 1-2 EOG redundant cables routed in three conduit The licensee initiated hourly fire watches. The licensee performed an engineering analysis (EA-FPP-95-04 7) which documented the acceptability of the existing configuration. The licensee's evaluation stated that the lack of a three-hour fire barrier *

was acceptable in this situation due to the low fire loading on each side of the barrier and, therefore, a fire on either side of the barrier would not propagate across the barrier and affect the redundant safe shutdown circuits. In addition, the evaluation concluded that the as-built configuration provided adequate protection and was acceptable per Generic Letter 86-1 On December 1, 1995, the licensee discontinued the hourly fire watches. During the inspection, the inspector reviewed the intake plenum area to the 1-1 EOG. The inspector noted that the 1-2 EOG circuits were routed within one to three feet from two

. air inlet vanes that provided air into the 1-1 EOG room. The vanes were approximately 36 inches in diameter and there was an inlet damper, between the vanes, that was closed shut but was not fire rated. A fire with the 1-1 EOG running could affect the 1-2 redundant circuits because of the large opening in the air intake vanes and the non-rated dampe On July 13, 1996, the N RC issued a severity level 111 violation for failure to correct several 1 O CFR 50, Appendix R, Fire protection deficiencies, one of which involved LER 95004. The violation involved the licensee's failure to perform an adequate evaluation of the air intake plenum area for the following reasons: (1) the analysis did not consider all possible failure modes for an operating diesel or operating modes of the diesel room ventilation system; (2) the analysis did not evaluate the potential impact of degraded or inoperable suppression systems; and (3) the methodology used to evaluate the fire severity was not conservative. On September 1996, the licensee revised the analysis to address the three NRC concerns. In addition, the analysis considered the equivalent fire resistance of the barriers between the 1-1 EOG room and the inlet plenum, the combustible loading within the rooms, the existing fire detection, the suppression

E8.17 E8.18 EB.19

systems and the ability of the barriers to prevent the spread of fire from one room to another. This item is unresolved pending further review to determine the acceptability of the licensee's present as-built configuration (50-255/98011-04).

(Closed) Licensee Event Report 95009: The licensee determined that the circuits for the low pressure safety injection (LPSI) pumps were not adequately separated to meet 10 CFR 50, Appendix R, 111.G requirements. The licensee's review indicated that manual operation of each pump's power supply breaker required that the breaker have control power. However, control power was defeated by the pump suction pres$ure interlock circuit failure. Therefore, the pump could not be started locally from the power breaker without pre-planned repairs and the existing procedures did not address the repairs needed to restore at least one LPSI pump in order to achieve cold shutdow On August 13, 1996, the NRC imposed a Severity Level Ill civil penalty for the licensee's failure to establish procedures that would have provided instructions for restoring the LPSI pump following a fire in the LPSI pump room. The details of the inspection were documented in inspection report 50-255/96004. The inspector verified that procedures No. EPS-E-7, "Local Tending of 2.4 KV Bus 1C Switchgear," Revision 7, and No. EPS-E-8, "Local Tending of Diesel Generator 1-2 (K-68) and 2.4 KV Bus 1D Switchgear," Revision 6, addressed operation of the power supply breakers. In addition, procedure No. ONP-25.2, "Alternate Shutdown Cooling Entry Preparations,"

Revision 15, provided instructions for replacing the control power fuses for the LPSI pump (Closed) Licensee Event Report 96005: The licensee determined that a fuse on the main supply to two safety related DC panels and the panel branch circuit breakers were not properly coordinated. The lack of coordination would allow a fuse to clear a fault on the main supply panel before the branch circuit breaker opened. The clearing of a fault in the main supply panel would cause the loss of the entire panel and thus, de-energize the safe shutdown equipment to which it would normally supply power. On August 13, 1996, the NRC issued a Severity Level Ill civil penalty for the licensee's failure to implement timely and effective corrective actions. The details of the inspection were documented in inspection report 50-255/96004. The inspector reviewed the calculations and specification change SC 96-022 that implemented actions to achieve proper coordination with the supply panel fuse and the branch circuit breakers. The inspector verified that the present fuse and breaker circuits were properly coordinated. The engineering interface and coordination among the licensee's organizations, to correct the problem, was goo (Closed) Licensee Event Report 96009: The licensee discovered two degraded fire barriers during walkdowns. It was discovered that Styrofoam insulation was used to fill the annular space around a duct penetrating the wall assembly that separated the 1-D switchgear room and the electrical equipment room.. In addition, an unsealed penetration was observed in the floor/ceiling assembly separating the cable spreading room from the 1-C switchgear room.. The licensee concluded that the safety significance to these rooms was low because the fire loading was low to moderate and the rooms were protected by sprinkler systems and smoke detection. The inspector verified that the licensee established hourly fire watches in these areas. The licensee

• issued a work order to place a qualified seal around the 1-0 switchgear duct and the electrical equipment room. With respect to the other degraded barrier that separate the

. cable spreading room from the 1-C switchgear room, the licensee planned to either seal the degraded barriers or submit an exemption request so that this area would be considered the same fire zone. This LER is closed based on licensee commitment At the conclusion of the inspection, the licensee still had the hourly fire watches in place in these area E8.20 (Closed) Licensee Event Report 97007: The contact on the emergency diesel generator sequencer load control relays were not tested as part of the Technical Specification test program. The function of these contacts was to provide a block signal to the SIS-X relays. Failure of this contact to open following an SI safety actuation signal, coincident with a loss of off-site power, would result in simultaneously loading all safety system loads onto the diesel generator as soon as the output breaker closed. This large load on the EOG would potentially result in the EOG breaker rapidly tripping on overcurren The inspector verified that these contacts were satisfactorily tested and were incorporated into the testing program in procedure No. RT-80, "Engineered Safeguards System - Right Channel," Revision 1 V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the in~pection on June 4, 1998. No proprietary information was identified by the licensee.

PARTIAL LIST OF PERSONS CONTACTED J. Ford, Manager, Energy Programs B. Dotson, Licensing R. Kilroy, Senior Engineer J. Kuemin, Programs and Systems Supervisor D. Malone, Licensing T. Newton, System Engineer

_ K. Toner, Licensing Supervisor R. Vincent, Licensing

• INSPECTION PROCEDURES USED IP 37550:

IP 92700:

IP 92701:

Onsite Engineering Licensee Event Reports Follow up IP 92702:

Follow up on Corrective Action for Violations And Deviations ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-255/98011-01 NCV The EOG fuel oil supply and associated piping did not meet licensing basis 50-255/98011-02 NCV Class IE and non-Class IE circuits were not isolated or separated as required by the FSAR 50-255/98011-03 URI Non-EQ cable installed in containment 50-255/98011-04 URI Redundant EOG circuits not separated per Appendix R requirements Closed 50-255/93012-00 LER CHP and CHR relays were determined not to be seismically qualified 50-255/93014-00 LER Electrical penetrations did not meet design requirements

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50-255/93026-05 VIO Lack of design control during implementation of a modification

50-255/93026-01 VIO (93277-01013)

50-255/93026-02 VIO (93277-02014)

50-255/94005-00 LER 50-255/94007-00 LER 50-255/94008-01 LER 50-255/94011-01 URI 50-255/94014-27 IFI 50-255/94014-2 IFI 50-255/94014-46 IFI 50-255/94014-55 IFI 50-255/94014-65 IFI 50-255/94015-00 LER 50-255/95004-00 LER 50-255/95009-00 LER 50-255/96005-00 LER 50-255/96009-00 - - l:ER.

50-255/97007-00 LER Design measures to change the engineered safeguards room cooler fan motor thermal overloads were inadequate CHP and CHR relays were determined not to be seismically qualified Redundant instrument cables routed in cable trays without separation barriers The EOG fuel oil supply and associated piping were not tornado protec Class IE and non-Class IE circ.uits were not isolated or separated as required by the FSAR Root cause for failure to separate Class e and non-Class e circuits Gear ratios of MOVs changed without knowledge of ISi department Relief valve setpoints did not appear to meet design requirements Root cause evaluations for apparent slow starts of the ED Gs Over-reliance on operator actions Improper control of vendor manuals Non-EQ cable installed in containment Redundant EOG circuits not separated per Appendix R requirements Circuits for the LPSI pumps were not adequately separated to meet Appendix R requirements Fuse to two safety related DC panels was not properly coordinated-255/97002-00

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Degraded fire barriers found during walkdowns Contacts on the EOG sequencer load control relays were not being tested

50-255/98011-01 NCV 50-255/98011-02 NCV The EOG fuel oil supply and associated piping did not meet licensing basis Class IE and non-Class IE circuits were not isolated or separated as required by the FSAR

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ASME CFR CET CHP CHR DET DRP DRS EOG EQ ERC FSAR IFI IP ISi LER LPSI MOV NRC NRR PCV TS URI VIO LIST OF ACRONYMS USED American Society of Mechanical Engineers Code of Federal Regulations Core Exit Thermocouple Containment High Pressure Containment High Radiation Diagnostic Evaluation Team Division of Reactor Projects Division of Reactor Safety Emergency D.iesel Generator Environmental Qualification Engineer Records Center Final Safety Evaluation Report Inspection Follow up Item

• inspection Procedure *

lnservice Inspection Licensee Event Report Low Pressure Safety Injection Motor Operated Valve Nuclear Regulatory Commission Nuclear Reactor Regulation Pressure Control Valve Technical Specification Unresolved Item Violation 13