IR 05000255/1999008
| ML18066A542 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/13/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18066A540 | List: |
| References | |
| 50-255-99-08, 50-255-99-8, NUDOCS 9907130179 | |
| Download: ML18066A542 (13) | |
Text
U.S. NUCLEAR REGULA TORY COMMISSION Docket No:
License No:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
REGION Ill 50-255 DPR-20 50-255/99008(DRP)
Consumers Energy Company 212 West Michigan Avenue Jackson, Ml 49201 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway
, Covert, Ml 49043-9530
_May 22 through June 30, 1999 J. Lennartz, Senior Resident Inspector R. Krsek, Resident Inspector E Cobey; Senior Resident Inspector, Byron Nuclear Plant Approved by:.
Anton Vegel, Chief Reactor Projects Branch 6 Division of Reactor Projects
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~907130179 990708
DR ADOCK 05000255 PDR
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EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRG Inspection Report 50-255/99008(DRP)
This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6-week period of resident inspection activitie Operations
Observations of control room activities were consistent with past performance.
Specifically, a professional atmosphere was maintained in the control room wh.ich was free of unnecessary activities and control room operators were knowledgeable of ongoing maintenance activities. (Section 01.1)
- The three hydrogen ignitions which occurred on June 9, 1999, during grinding operations of Multiassembly Sealed Basket Number 15 were of minor industrial safetY significance. However, plant personnel did not communicate the issues to on-shift operations personnel or plant management until the next morning. Consequently, several opportunities were missed to preclude recurrence of the incident in a timely manner.* Upon notification, plant management initiated timely and comprehensive corrective actions. (Section 01.2)
The operator's actions to roll Emergency Diesel Generator 1-2 after water was identified in cylinder 1 R during surveillance testing were ill-informed. The actions were taken prior to obtaining a recommendation from engineering personnel which was not typical.of past performance. Also, the.documented guidance in the operating procedures was not
. clear which contributed to the operators taking actions that would not hav~ been recommended by engineering. (Section 03.1)
Auxiliary operator5 effectively monitored Emergency Diesel Generator 1-2 parameters which resulted in the timely identification of abnormal lube oil pressure. As a result, the *
Emergency Diesel Generator was manually tripped before lube oil pressure dropped'
below the acceptable limit. This precluded a challenge to the low lube *oil pressure
. automatic trip. (Section M1.2).
- Operations personnel appropriately used risk assessment information during the performance of emergent maintenance activities which demonstrated a positive focus on safety. (Section M1.2)
Maintenance
Maintenance and.surveillance activities observed were performed with the procedures*
and work packages at the job site and actively being used. System engineers and
_________ * ________ majntenance Sl!P-~l'.Y~Qrs y.iere f!~~~'!.tlX C?.!?.~~!'Y_ed_~t _t~~j_~~--location providing technical support to maintenance technicians. (Section M1.1) **
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Emergent maintenance was completed in a skillful manner on Emergency Diesel Generator 1-2 as evidenced by the lack of rework. Thorough support was provided by maintenance planning personnel and maintenance supervisors. Required maintenance
'.
rule evaluations were documented in condition reports and considered appropriate. The post-job critique was self-critical and effective. (Section M1.2)
An operations representative did not attend the post-job critique which was considered a *
potential detriment to the effectiveness of the critique process. (Section M1.2)
Engineering
- System Engineering support during the emergent maintenance activity on Emergency.
Diesel Generator 1-2 was thorough and pro-active. (Section E2.1)
Plant Support
Radiological protection personnel and security personnel provided thorough support during the transport of Ventilated Storage Cask #15 to the dry fuel. storage area on June 18. (Section 58)
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Report Details Summary of Plant Status
- The plant operated at full power for the duration of the inspection period. One significant equipment problem emerged regarding Emergency Diesel Generator 1-2 as discussed in Section M1.2 of this report. The Emergency Diesel Generator problem was resolved within the Technical. Specification allowed outage time which prevented a challenge to plant operatio I. *Operations
'01 Conduct of Operations
.
.
0 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations in the control room. The inspedors noted that a professional atmosphere was maintained and that.*.*
the control room was free of unnecessary activities, Log keeping was tho'rough and *
.. *complete with a few minor exceptions. Control room operators were knowledgeable of
. ongoing maintenance activities and.the reason that annunciators were in an alarm
. *status. The inspectors concluded that these obser'Vations regardi_ng control room activities were con~istent with past performanc *
0 Dry Fuel Storage Activities
- Inspection Scape !71707 and 60855)
The inspectors observed the licensee's response to three hydrogen ignitions which 6ccurred duririg grinding operations of the structural lid for Multiasserribly Sealed Basket* '
(MSB) Number 15. The inspectors discussed the incident with the personnel involved,.
walked down the MSB wqrk area, and assessed the plant personnel's response to the.
incident upon discover *
b. *.
Observatio~s and.Findings On the morning of June 10, 1999, licensee management ~as informed that at approximately 7:30 p.m. on June 9, a welder observed and immediately extinguished a small flame at the discharge end of the MSB vent tube during grinding operations. The
- MSB vent tube removed any hydrogen produced within the MSB. The discharge end of the MSB vent tube was normally attached to the inlet of an air filter; however, during the
. course of wor:k. the vent tube became separated from the air filter inlet. Sparks from the * ** *
structural lid grinding operation ignited the hydrogen gas vented from the MSB at the discharge end of the MSB vent tube. Upon observation of the small flame, the welder crimped the MSB vent tube which immediately extir:aguished the flame. The shift lead
--,-------constr:uction_super:visorstopped worlcand_notified_personnelJnJheLspentJueLproject group. The discharge end of the MSB vent tu.be was reconnected to the air filter inlet, additional hydrogen gas readings were taken in the work area, and work activities were resumed.
Upon being notified of the incident on June 10, licensee management stopped all dry fuel storage work pending further investigation of the inci.dent. Condition Report C-PAL-
. ';.. was generated and the Plant Manager formed an incident response team (IRT)
to obtain the facts surrounding the event. Initial interviews conducted by the IRT With
.the personnel involved with the MSB work revealed that a second incident had occurred at 5:30 p.m.*on June 9. However, the personnel who observed and extinguished the small flame did not consider the fire significant and did not communicate the incident to the shift lead construction supervisor. Consequently, the information was not passed on to the next shift of worker The IRT interviews also revealed that two small flames, rather than one, had been
- observed on June 9, at approximately 7:30 p.m. The Shift Supervisor, who was the senior licensee representative onsite at the time of the incidents, was not informed of any of the incidents. In addition, a condition report, which would have communicated the incidents to other pl~nt personnel, was not initiated until the morning after the incident Overall, the hydrogen ignitions were considered a minor industrial safety issue.
. However, the failure to communicate the occurrence of the unexpected conditions expeditiously to the appropriate plant management, was inconsistent with plant management's expectations.* Consequently, several opportunities were missed to preclude this incident from recurring. Upon discovery, plant management took timely:
and comprehensive corrective actions to prevent this incident from recurrin Conclusions
... *
The inspectors concluded that the three hydrogen ignitions which occurred during
- grinding operations of the MSB were of minor industrial safety significance. Howev~ the failure to communicate the issue to on-shift operations personnel and to plant *
management in a timely manner was not consistent with plant management's
expectations. Consequently, opportunities were missed to preclude recurrence of the inciden, 03 Operations Procedures and Documentation 0 Operation of Emergency Diesel Generator CEOG) 1-2 Inspection Scope (71707)
The inspectors reviewed the EOG operating procedures to assess the guidance that
. was available to the operators if water was identified in a cylin.der. Also,. the inspectors reviewed condition reports that were generated during the emerg~nt maintenance activities associated with EOG 1-2 (see Section M1.2.for details)..
b.,
Observations and Findings
-. --en-.June-20;-19991 the-licensee -initiated.Condition_Report99-:0.932to_ do_cum~nt th~t ___ _
water was identified in EOG 1-2, cylinder 1 R during surveillance testing. After water was identified in the EOG cylinder, operations stopped the surveillance test*and attempted to
- call engineering personnel who were not immediately available. Operations
subsequently discussed the problem with i;in engineering representative a couple hours later. However, operations personnel rolled the EOG several times in an effort to further evaluate the problem before they were able to consult with engineerin **
Based on subsequent discussions with engineering personnel, the actions taken by operations personnel would not have been recommended because of the potential to cause internal damage to the EOG due to a hydraulic lock of a water filled cylinde While no additional damage occurred to the EOG, the inspectors determined that the actions taken by operations personnel to roll the EOG after water was identified in cylinder 1 R were HI-informed, and not typical of past performance. Past observations by the inspectors revealed that, typically, operations consulted with engineering personnel prior to performing any troubleshooting activities When problems of unknown significance regar~ing safety related equipment emerge Based on discussions with opercitions management, rolling the EOG after water was identified in cylinder 1 R was allowed by the procedure in that it was performed as an effort to further evaluate the problem. The inspectors reviewed the procedures and noted that the documented guidance was unclear; Specifically, one procedural step that stated "suspend testing until the condition has been appraised" was interpreted
differently by operations and engineering personnel. Operations interpreted it to mean
. to not go forward with the surveillance test until the problem was evc:iluated furthe Engineering interpreted it to mean to stop the surveillance test and do nothing until consulting with engineering. Consequently, operations took actions that would not have been recommended by engineering personnel. Therefore, it appeared that procedural enhancements were required. Condition Report 99-0995 was _generated to evaluate the proble Conclusion The inspectors concluded that the operator's actions to roll EOG 1-2 after water w~s-ide.ntified in cylinder 1 R were ill-informed. The actions were taken prior to obtaining a
... recommendation from engineering personnel which was not typical of past performance.
.. Also, the documented guidance in the operating procedures was.not clear which
contribllted to the operators taking cictions that would not have been recommended by engineering. *
Miscellaneous Operations Issues (92901)
0 (Closed) Violation 50-255/98007-02: "Inadequate Surveillance Test Procedure." The licensee identified, during a* post-implementation review of Technical Specification
.surveillance Test-Procedure RT-718, "High Pressure Safety Injection Train 1and2 and Safety Injection Tank System, Class 2 System Functional/lnservice Test:" Revision 3,
- that the performance of the procedure rendered both trains of the High Pressure Safety
- Injection System inoperable. As a result, the licensee submitted Licensee Event Report
- * 50-255/98007, "High Pressure Safety Injection System lnoperability During Technical Specification Surveillance Test." The inspectors reviewed the licensee's corrective actions and concluded that they were acceptable. This item is close *---- --- ------ *- --*-- ----* ---_ -
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- II. Maintenance M1 Conduct of Maintenance M1.1 General Comments (61726. 62707. 71707)
The inspectors reviewed all or portions of the following maintenance work orders and surveillance activities. Also, the inspectors reviewed Technical Specifications and the
. Final Safety Analysis Report when applicabl *
Work Order No:
24911830
24911869 Surveillance No:*
- Rl-62C
M0-7A-2
Q0-19A
00-42C Emergency Diesel Generator (EOG) 1-2, Replace Cylinder Head 1R Emergency Diesel Generator (EOG) 1-2, Replace Attached Lube Oil Pump
Power Range*safety CIJannel Ali~nment-Chanriel C Emergency Diesel Generator 1-2 lnservice Test Procedure - High Pressure Safety Injection Pumps.
and Engineered Safeguards System Check Valve Operability Test Section XI Testing of Shutdown Cooling Control Valves The inspectors noted that the maintenance and surveillance activities observed were
- performed with the procedures and work packages at the job site and actively being used. *system Engineers and maintenance supervisors were frequently observed at the job location. Activities completed in the control room were performed in a professional *
manner and coordinated with the control room operator M1.2 * Emergent Maintenance On Emergency Diesel Generator (EOG) 1-2
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a. :
Inspection Scope (62707. 37551. 71707)
The inspectors observed portions of EOG 1-2 emergent maintenance activities to replace the head on cylinder 1 R and to replace the attached lube oil pump. In addition, the inspectors reviewed the applicable work ord.ers and condition reports, verified the accuracy of the associated tagout, and observed the post-job critiqu *
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On June 20, 1999, while performing EOG 1-2 cylinder leak tests associated with the Technical Specification monthly surveillance, operations personnel identified water in cylinder 1 R. Consequently, the EOG was declared inoperable, the monthly surveillance was suspended,* and troubleshooting was initiated to determine the source of the wate Engineering personnel concluded, based on sample results, that EDG 1-2 jacket cooling water was the source of the leak. A maintenance plan was established and potential leak paths were identified and prioritized. Engineering personnel consulted with the vendor and noted that the most likely leak path was from the fuel injector sleev *
However, after the cylinder head was removed, a visual inspection revealed only a *small corrosion area in the vicinity of the sleeve but did not confirm the leak path. Therefore, the cylinder head was sent. to the vendor for hydrostatic testin Hydrostatic testing identified that there were two cracks in the cylinder head which provided the leak path for jacket cooling water. After the leak source was confirmed, maintenance personnel installed a new head on cylinder 1 R and turned the EDG over to operations for post-maintenance testing. The vendor was planning to perform a root cause analysis on the failure mechanism for the cracks in the cylinder head. Based on discussions with engineering personnel, the inspectors were informed that the results from the analysis would be factored into the pending maintenance rule evaluation associated with Condition Report C-PAL-99-0932 which was*considered appropriate~
D~ring subseq.uent post-maintenance testing of the EDG, the auxiliary operators noted that lube oil pressure was oscillating and slowly trending down. Consequently, the EDG was tripped. Auxiliary operators effectively monitored the EDG that resulted in quickly identifying the abnormal decreasing lube oil pressure. Therefore, the EDG was manually tripped before lube oil pressure dropped below the acceptable limit. This prevented a challenge to the low lube oil pressure automatic trip of the ED Engineering personnel suspected that the internal relief valve on the attached lube oil*
pump was lifting. Subsequently, maintenance technicians replaced the attached lube oil
_pump and the associated relief valve. Engineering personnel planned to send the attached lube oil pump and internal relief valve to the vendor for analysis. Based on discussions with engineering personnel, the inspectors noted that the results from' the*
analysis would. be factored into the pending maintenance rule evaluation associated with Condition Report C-PAL-99-0955 which was considered appropriat On June 25, 1999, the EDG satisfactorily passed the technical specification surveillanee test and was declared operable.. The emergent maintenance was completed within the *
allowed outage time to prev~nt a challenge to plant operations. Also, the inspectors noted that the maintenance technicians completed the emergent repairs in a.skillful manner as evidenced by a lack of rewor '
The insp.ectors. noted that operations personnel appropriately used risk assessment.
information during the emergent maintenance which demonstrated a positive focus on safety. For example:
Emergency Diesel Generator 1-1 was tested in accordance with Technical
. Specification requirements after EDG 1-2 was declared inoperable. During the
--,--*-----*---- - - --test, ~EE>G--1-twas-declared inoperable_and.therefore., _a r_i_s!<.. c:!~~~ssment based on both EDGs being inoperable was completed prior to testing EDG 1 ~1 :* The----------
Risk Achievement Worth increased to 15.4 which was considered high ris Therefore, operations personnel received plant management approval priqr to performing the test start on EDG 1-1 as require Also, the inspectors noted that engineering personnel and maintenance planning personnel provided thorough support for the emergent maintenance by immediately implementing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage (see Section E.2 for additional discussion on engineering support). In addition, Work Week Managers started 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage two days into the emergent activity to provide additional suppor Some additional noteworthy observations regarding the emergent maintenance activities included:
A pre-job brief was conducted to remove and replace the attached lube oil pump and associated relief valve. The briefing adequately covered the work order and specific responsibilities for the work groups involved. Also, the briefing highlighted safety concerns for both the maintenan~,staff as well as other plant personne *
However, maintenance technicians expressed concerns regarding the format of the work order in that the use of very specific and detailed steps could cause
problems for the work involved. The maintenance technicians then questioned if the work order had to go back to planning if the work order steps had to be deviated from or was it considered in the skill of the craft. No definitive answer was provided by the maintenance supervisor conducting the pre-job brief. In subsequent disaissions with maintenance technicians, the inspectors noted that*
work would be stopped if problems emerged regarding the work order. Also, the inspectors did not observe any problems related to the work order during the maintenance activitie *
Operations personnel identified, prior to testing, that the post-maintenance*.
testing specified in the work order was inadequate. The testing did not include verification that a ventilation damper that had to be removed for the maintenance operated properly. Removal of the ventilation damper was a change to the original workorder; however, the post-maintenance testing requirements did.not get revised accordingly. Condition Report 99-0967 was generated to doc\\jment *
the problem with the specified post-maintenance testin Post-maintenance testing requirements were revised appropriately after the problem was identified and testing was completed satisfactorily, However, the
. inspectors noted an apparent vulnerability in the licensee's process. The Work.'..
Control Center reviewed the post-maintenance testing requirements on the
- original work order butthe revised work order was not routed back to the Work Control Center. Consequently, an oppo.rtunity was missed to revise the post-maintenance testing requirement *
A post-job critique that was conducted to capture lessons learned during the emerge_nt maintenance was considered effective. Several areas for
- ----*---*------ *~improvementwere identified by_li~11.§..e_e_~~rsonnel involved and the inspectors considered the critique as self-critica ~- * * -----------*-- _,, _______.. __ _
However, the inspectors noted that there was not a representative from operations department at the critique. Consequently, problems identified by operations were not provided at the critique and*problems pertaining to operations that were identified by other work groups could not be adequately
- addressed. The inspectors viewed this as a potential detriment to the effectiveness of the critique proees Conclusions The inspectors concluded that the emergent maintenance on EOG 1 ~2 was completed in a skillful manner as evidenced by the lack of rework. Thorough support was provided by
- maintenance planning personnel and maintenance supervis<;>rs. Required maintenance rule evaluations were documented in condition. reports and considered appropriate. The post-job critique was self-critica However, an operations representative did not attend the post-job critique which was considered a potential detriment to the critique process. Also, an apparent vulnerability was identified regarding the licensee's process to identify required post-maintenance testing. The work group that.reviewed testing requirements on the original work order did not necessarily review the work order for needed changes to the testing requirements if the work order was subsequently revised. However, the vulnerability did
- * not result in *any adverse consequence *Auxiliary operators effectively monitored EOG parameters which resulted in the timely identification of the abnormal lube oil pressure. Therefore, the EOG was manually *
tripped before lub~ oil pressure* dropped below the acceptable limit. This precluded a challenge to the low lube oil pressure automatic trip. Also, the inspectors concluded that operations personnel appropriately used risk assessment information during the performance '9f emergent maintenance activities which demonstrated a positive focus on safet *
Ill. Engineering
- E2 Englnee~lng Support of Facilities and Equipment E Emergency Diesel Generator CEDG) 1-2 Maintenance and Testing Inspection Scope (37551)
b..
The inspectors obs~rved troubleshooting and testing activities associated with the emergent maintenance on EOG 1-2. Also, the inspectors reviewed the operability recommend.ations that were provided to oper_atiqns by engineerin *
Observations and Findings System Engineering implemented 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage immediately after being notified of
- the problem regarding water in cylinder 1 R on EOG 1-2 and maintained 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage ontil-theproblem*was-resolved~-*SystemEngineering_pe.r:soooelw.ere RIQ.:-__ _
. active in resolving the problem. The vendor was consulted and a detail.ed
troubleshooting plan was developed with appropriate contingencies identified. The inspectors noted that engineering personnel frequently monitored ongoing maintenance and testing activities. Also, operability recommendations provided to operations were timel *
- E8 E Conclusions The inspectors concluded that System Engineering support cluring the emergent maintenance on EOG 1-2 was thorough and pro-activ Miscellaneous Engineering Issues (92903)
(Closed) Licensee Event Report (LER) 96-014: "Class 1 E Raychem Cable Splices Installed Incorrectly." On November 24, 1996, during a routine refueling outage, the licensee identified that Class 1 E electrical cable splices were installed incorrectl Licensee personnel generated Condition Report C-PAL-96-1579 to document the adverse condition. *
A total of 381 splices within containment were identified as potentially being.affecte Following an inspection of all of the splices, 270 were replaced with correctly installed splices, and the remaining 111 splices were determined to be acceptable. Susceptible *
cable splices located in potentially harsh environments outside containment were also evaluated and determined to be qualified by analysis, in accordance with 10 CFR 50.49 In addition, the splices that were removed were evaluated to determine the capability of the cable splice configuration to meet the postulated accident conditions within
- containment during prior qperation.. The evaluation concluded that the incorrectly *
installed splices would have performed their required safety function during any" Desig_n
. Ba~is Aecident. Therefore, the event was not significant to safety because operability of the.affected equipment was not i.mpaire *
The.licensee's evaluation of C-PAL-96-1579 concluded tha! the root cause for the incorrectly installed splices was an inadequate installation procedure, Maintenance Procedure MSE-E-5. However, the inadequate procedure did not result in any equipment operability concerns. Therefore, this failure constitutes a violation of minor significance and is not subject to *formal enforcement action. The inspectors reviewed
- the*corrective actions and concluded that they were reasonable. This item is closed. *
IV. Plant Support
.sa Miscellaneous Radiological Protection and Chemistry Controls (71750)
The inspectors observed portions of transporting Ventilated Storage Cask #15 to the dry fuel storage area on June 16, 1999. The inspectors noted thatradiological protection technicians provided continuous coverage during the activity and that the personnel *
di.rectly involved with. moving the cask wore appropriate dosimetry. In addition, the inspectors noted that security personnel provided comprehensive support during the
-:--c--- ___ :.._time that the associated security fences were breached for the transport. The
inspectors concluded *fffafsiippO-rr-p-rovided-by radiolo~ical-protection-personneLand _____ _
security personnel during the transport of Ventilated Storage Cask #15 to the dry fuel stora~e area was thoroug Quality Assurance in Fire Protection Activities (71750)
The inspectors observed the fire brigade respond to an.alarm in the Auxiliary Building on June 18, 1999. Subsequently, the licensee determined that an actual fire did not occu In addition, the inspectors reviewed the condition report that was generated because of comments presented at the post-response critique. The inspectors noted that the fire brigade responded in a timely manner and that appropriate fire fighting equipment was donned. A post-alarm response critique was conducted with the fire brigade members and operations shift management. Condition Report C-PAL-99-0928 was generated to document the issues raised during the critique. The inspectors concluded that the condition report demonstrated an appropriate sensitivity for problem identificatio V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on July1 1, 1999.* The licensee acknowledged the findings presented. The inspectors asked the license whether any materials _examined during the inspection should be considered_ proprietary. No proprietary information was identifie.__, _______ -------
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Licensee PARTIAL LIST OF PERSONS CONTACTED G. R. Boss, Operations Manager N. L. Haskell, Director, Licensing D. G. Malone, Licensing R. L. Massa, Shift Operations Supervisor T. J. Palmisano, Site Vice President '
D. W. Rogers, General Manager, Plant Operations R. G. Schaaf, Project Manager, NRR INSPECTION PROCEDURE$ USED IP 37551:
IP 61726:
IP 62707:
IP 60855:
IP-71707:
IP 71750:
- IP 92901:
IP 92903:
IP 92700:
Opened None Closed Onsite Engineering Surveillance Obs~rvations Maintenance Observations Dry Fuel Storage Operations Plant Operations Plant Support Activities Followup Operations *
Followup Engineering
- LER Followup
'
ITEMS OPENED, CLOSED, AND DISCUSSED 50-255/98007-02 VIO
. Inadequate Surveillance Test Procedure 50-255/96014 LER Class 1 E Raychem Cable Splices Installed Incorrectly *
Discussed
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