ML18043A387

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IE Insp Rept 50-255/78-25 on 781016-20.Noncompliance Noted: Failure to Implement Procedure,Perform Surveillance & Technical Audit, & Improper Implementation of QA Procurement Requirements
ML18043A387
Person / Time
Site: Palisades Entergy icon.png
Issue date: 11/29/1978
From: Hunter D, Jorgensen B, Warnick R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18043A385 List:
References
50-255-78-25, NUDOCS 7901120007
Download: ML18043A387 (11)


See also: IR 05000255/1978025

Text

L

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No.

50-255/78-25

Docket No.

50-255

Licensee:

Consumers Power Company

212 West Michigan Avenue

Jackson, MI

49201

Facility Name:

Palisades Nuclear Plant

License No.

DPR-20

Inspection At:

Palisades Site, Covert, MI and Consumers Power

Company, Jackson, MI

Inspection Conducted:

October 16-20, 1978

RFW F--

Inspectors:

D. R. Hunter

11-2...'f-?e

RFW ~

B. L. Jorgensen

11-e9. 'B

RFW~

Approved By:

R. F. Warnick, Chief

Reactor Projects Section 2

II- 2'1*7~

Inspection Summary

Inspection on October 16-20, 1978 (Report No. 50-255/78-25)

Areas Inspected:

Routine, announced inspection of licensee actions

on previous inspection findings, plant operations, licensee review

and audit programs, quality assurance items, procurement, maintenance,

independent inspection effort, followup on outstanding inspection

items, and reportable events.

The inspection involved 79 inspector-hours

onsite and in the licensee's corporate offices by two inspectors.

Results:

Of the eight areas inspected, no apparent items of non-

compliance were identified in five areas.

Four items of noncompliance

were identified in the other areas (infraction - failure to implement

procedure - paragraph 3.c; deficiency - failure to perform surveillance-

paragraph 3.d; infraction - failure to complete technical audit program -

paragraph 4c; and deficiency -

improper implementation of quality

assurance requirements for procurement - paragraph 6.b.)

790112000,

1.

DETAILS

Persons Contacted

a.

Corporate Offices

  • F. Buck.man, Director, Nuclear Activities Department (NAD)
  • D. Noble, Director, Operating Services Department (OSD)
  • D. Bixel, Nuclear Licensing Administrator
  • L. Hausler, Administrator, Construction Coordination (OSD)

K. Andrews, Supervisor, Laboratory Technical Services

G. Ridge, Supervisor, System Protection

J. Fremeau, Administrator, Operations Quality Assurance

D. Hoffman, Assistant Nuclear Licensing Administrator

S. Cashell, Licensing Analyst - Palisades

  • Present at management interview October 18, 1978.

The inspectors also interviewed several members of the

engineering and technical staffs of the Nuclear Activities

Department, Operating Services Department, Laboratory

Technical Services, and System Protection.

b.

Palisades Plant

  • J. Lewis, Plant Superintendent
  • H. Keiser, Operations Superintendent
  • K. Berry, Technical Superintendent
  • G. Hein, Maintenance Superintendent
  • J. McVay, Administrative Supervisor
  • R. Mccaleb, Quality Assurance Superintendent
  • H. Plamer, Senior Engineer

G. Petitjean, Technical Engineer

E. Huss, Plant Stores Supervisor

J. Reinier, Quality Control Inspector

F. Butler, Instrumentation and Control Engineer

R. Vincent, Senior Engineer

E. Thompson, Shift Supervisor

A. Brookhouse, Shift Supervisor

J. Richter, Control Operator

T. Richards, Control Operator

  • Present at management exit interview October 20, 1978.

The inspectors also contacted several other members of the

plant technical, operations, maintenance, and administrative

staffs.

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2.

Licensee Action on Previously Identified Items

(Closed) IE Inspection Report No. 50-255/78-08 - unresolved item:

Qualification of the containment connector seal washers/0-rings.

(Paragraph 8).

3.

Plant Operations

The inspectors reviewed selected facility records and general

plant operating conditions to ascertain the plant was being

operated in accordance with the requirements.

a.

Shift Supervisor Log, October 1978.

b.

Control Room Logbook, October 1978.

c.

Reactor Logbook, October 1978.

(1)

The review revealed that following a plant trip on

October 17, 1978, (due to the loss of a main feed

pump), a reactor system pressure decrease occurred

and the operating crew blocked safety injection

after the "BLOCK PERMISSIVE" was received at 1690 psia

decreasing.

The safety injection system "BLOCK" was

automatically removed after approximately seven (7)

minutes as the system pressure recovered from a

minimum of 1610 psia.

Immediately prior to the reactor trip the reactor

operator emergency borated the RCS for a short period

of time.

After completing the normal operator

response to a plant trip, including verifying all

rods fully inserted, safety injection initiation was

"BLOCKED" as the primary coolant system pressure

continued to decrease below 1690 psia.

The momentary

plant cooldown to approximately 505°F and depressuriza-

tion to 1610 psia was caused by the continuation of

feedwater flow to the steam generators following the

reactor trip.

A review of the transient by the licensee and inspectors

determined that with the reactor tripped and all rods

fully inserted at 500°F Tavg, the plant shutdown margin

was approximately 5.5 percent, well in excess of that

required by the accident analysis.

The calculated

shutdown margin at 60°F Tavg with all rods fully inserted

was approximately 2.8 percent, also in excess of the

requirements.

The licensee's approved operating procedures stipulate

when safety injection may be "BLOCKED".

According to

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(2)

procedures AS.9, Plant Cooldown from Hot Standby,

and SOP-1 step 6.1.6, Cooldown of Primary System

from Hot Hot Standby, boration to the cold shutdown

boron concentration is to be accomplished before

blocking the safety injection signal.

Procedure D4.l,

Reactor Trip, does not address blocking the safety

injection signal.

The failure to follow the

approved operating procedures, as required, is an

item of noncompliance pursuant to Technical Speci-

fication 6.8.1 and is an infraction.

(This matter

was discussed at the management exit).

The reactor log review also revealed that the operations

group was encountering difficulty maintaining certain

heat traced points for the chemical and volume control

system above the system alarm points of 135°F.

The

inspectors reviewed the auxiliary operator log sheets

for September and October 1978, and selected strip

charts for the temperature recorder associated with

the critical heat tracing system (TR-200) to insure

that the concentrated boric acid lines were being

maintained above 110°F.

The inspectors noted that

the temperature of the "B" boric acid transfer pump

and associated piping appeared to be routinely between

125°F and 135°F (17 times in September and October, 1978).

The log review revealed that the operators were routinely

operating the "B" boric acid transfer pump to return

the pump and piping to above 135°F.

The inspectors also noted that on September 7-8 and

October 16-17, 1978, the concentrated boric acid

gravity flow line had decreased below 135°F on several

occasions.

The inspectors verified that, during the periods

reviewed, no heat traced lines indicated below a

temperature of 110°F.

All concentrated boric acid

paths appeared to be operable, including the "A" and

"B" boric acid tanks, "A" and "B" boric acid transfer

pumps, emergency borate flow path, and the "A" and

"B" gravity flow paths.

(This matter was discussed

at the management exit).

d.

Selected Plant Recorders and Indications

The review revealed that the secondary rod position typer

had been removed from service during the swing shift

(4:00 p.m. - 12:00 p.m.) on October 18, 1978, and remained

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out-of-service until October 20, 1978.

The secondary typer

was being used in the place of the failed primary typer.

During the period the secondary typer was out-of-service

the comparison of the secondary rod position and the primary

rod position systems was not performed as required by the

Technical Specification, Table 4.1.3, item 3a (Shift Check,

SH-1).

The inspector verified that the rods were within

requirements on October 18, 1978, prior to removal of the

secondary typer.

The control rods had not been moved in the

interim period and no indications were received during opera-

tions from the power range instrumentation or the incore

power monitoring system of a drifting control rod.

The

failure to perform the shift checks, as required, is an

item of noncompliance and is a deficiency.

(This item was

discussed at the management exit).

e.

Plant Annunciators

f.

g.

The inspectors noted the continuation of the "BORIC ACID

HEAT TRACE TROUBLE" alarm and verified the continuation of

the ~hift survrfllance and status of the critical heat

tracing system- .

Control Room Manning and Shift Relief

Safety Related System Status

The inspectors noted that the 1-1 and 1-2 emergency diesel

generator (EDG) control switches were caution tagged to

indicate outstanding maintenance activities concerning the

1-1 EDG day tank and the 1-2 EDG air start motor.

The

inspector verified that both the emergency diesel generators

were operable.

h.

Shift and Relief Turnover

i.

Plant Housekeeping/Cleanliness

No other items of noncompliance or deviations were identified.

4.

Review and Audit

The inspectors reviewed the activities of the Safety and Audit

Review Board (SARB) as evidenced by SARB meeting minutes for 1977.

In addition, conduct of technical audits of licensed activities

for the SARE was specifically examined.

1/ IE Inspection Report No. 50-255/77-17.

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a.


*---~-------

SARE activities were reviewed in comparison to Technical

Specification requirements concerning functions, composition

and qualifications, meeting frequency, review items, and

records.

No problem areas were identified.

b.

The licensee's technical audit program is controlled by

Technical Specification 6.5.2.8, which assigns responsibility

for conduct of these audits to the Operating Services Depart-

ment, with review by SARB.

The inspectors noted a revision

c.

of the licensee's Quality Assurance Program Procedure (QAPP)

18-51, Audits, dated December 23, 1977, which reassigns

responsibility for technical audits in some areas to the

Nuclear Activities Department.

This change in the assignment

of responsibility for technical audits requires further review.

The inspectors reviewed selected technical audit reports

for audits conducted in 1977, and discussed audit methods

and findings with those performing selected audits.

The

technical audit program was also reviewed for completeness.

The licensee's procedure (QAPP 18-51, Audits) describes

the auditing program areas which must receive at least one

audit per year.

This program is established to satisfy

Technical Specification provisions and license conditions.

QAPP 18-51 includes, as functional audit areas, both health

physics and reactor physics, among others.

The inspectors

noted no audits of health physics or reactor physics had

been performed in 1977, nor had the licensee formally recog-

nized this oversight and taken corrective action to complete

these audits in early 1978.

Failure to perform the specified

technical audits constitutes noncompliance with Technical

Specification 6.5.2.8.a and is an infraction.

The identified noncompliance was discussed during management

exit interviews at the licensee's corporate offices on

October 18, and at the plant site on October 20, 1978.

No other items of noncompliance or deviations were identified.

5.

Quality Assurance Items

The inspectors examined the licensee's program for control of

measurement and test equipment as specified in his Quality

Assurance Policy (QAP) and Procedures (QAPP's).

The examination

included a review of assignments of responsibility and authority,

procedural controls, and proper program implementation *

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a.

Control of measurement and test equipment, as it relates to

calibration and testing of portable plant instrumentation

and certain installed plant electrical relaying and trip

devices, is the responsibility of Laboratory Technical

Services.

Engineering development relating to electrical

relaying and trip setpoints is the responsibility of System

Protection.

Both these organizations were visited by the

inspectors; procedures and practices were reviewed and dis-

cussed with appropriate staff; and a brief tour of the

Laboratory Services facilities was conducted.

The review of the relay testing performed for the plant by

the System Protection and Laboratory Services group revealed

that the 480 volt AC switchgear and motor control center

magnetic and thermal overload trip devices had not been

tested, except during maintenance on a specific component,

since plant startup.

These trip devices require special

testing equipment which provides the actual trip current

to the breaker and trip unit.

(This matter was discussed

at the management exit).

No items of noncompliance or deviations were identified.

6.

Procurement

a .

General

The inspectors reviewed the following relating to procurement

of safety related components:

(1)

Procedures and practice for selection of suppliers

(2)

Processing of documentation

(3)

Receipt, inspection, and storage

(4)

Disposition of nonconforming items

b.

Procurement Document Review

Several procurment packages were reviewed in detail, including

packages relating to electrical, control rod drive, reactor

coolant, and steam systems.

These generally showed complete

conformance to quality assurance program requirements.

One

case was noted, however, where a number of components in a

large order were received onsite without copies of various

test results included as specified in the procurement documents.

Such components were initially held and a nonconforming

material report (NMR) issued for processing and disposition

of the components in question.

Use of the NMR system did

not appear well controlled in this case, resulting in the

following:

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"

c .

(1)

Mistaken acceptance of an item, missing a certified

material test report, on the basis of a dimensional

check having been performed.

(2)

An NMR missing from the procurement package being

referenced as the basis for acceptance of a component.

(3)

Rejection of a certified but undocumented component

based on performance of the required test in the field.

Further, several components (under Purchase Order No. 93282)

were accepted through the NMR system without acquiring test

data specified on the procurement document.

This prevents

an objective evaluation of conformance to acceptance criteria.

Criterion VII of Appendix B to 10 CFR 50 requires evidence of

conformance to procurement documents to be available at

the power plant prior to installation or use.

The licensee's

failure to acquire the test data specified on the procurement

order is considered to be in noncompliance with Appendix B

and is a deficiency.

This matter was discussed at the plant

exit interview on October 20, 1978.

Storage of Safety-Related Items

The licensee has relocated his storage facilities in the past

year to space in a new building.

The storerooms were toured

and the inspectors checked proper storage, organization and

cleanliness.

Storage of2¥iping and tubing with ends capped

was specifically check39-

and found satisfactory.

Some

holes were again noted-=-

in the plastic coverings for eves

filter assemblies.

This was corrected and checked prior to

completion of the inspection.

Finally, the inspectors noted

ovens for storage of weld rods intended for use in safety-

rela ted systems were not provided with temperature indicators

to show continuous temperature in the required range.

Since

the licensee has no reheat capability onsite, these ovens are

relied on to maintain moisture control.

(The storeroom items described above were discussed at the

plant management exit interview)

7.

Maintenance

The inspectors reviewed selected maintenance activities to assure

that the activities were conducted in accordance with the require-

ments.

The activities reviewed included:

2/ IE Inspection Report No. 50-255/77-14.

J/ Ibid.

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a.

77-MSS-106-05, Steam Generator Recirculation System.

b.

77-NMS-102, Removal of NMS Drawer 06 for Overhaul.

c.

77-SWS-28-07, Service Water Valve, CV-0823.

d.

77-SWS-37-06, Service Water Pump Repair.

No items of noncompliance or deviations were identified.

8.

Outstanding Inspection Items

4/

51

6!

71

81

The inspectors reviewed the following items to insure appropriate

action taken and completed by the licensee:

a.

b.

c.

d.

Containment Penetrations Connector Sealing Washer/0-rings.!:/

The inspectors reviewed the documentation available for cer-

tification of the silicone sealing washers based on materials

and testing performed at Wyle Laboratories (STAN-07-78) and

letters from Bendix dated June 16, 1978, and July 11, 1978.

No further questions are required of this matter at this time

and this item is considered closed.

Fire Protection Supply to Auxiliary Feed Syste~/

The licensee has included the manual flow path from the fire

protection system to the suction header of the auxiliary

feed pumps in the Section XI testing program.

No further

questions are required of this matter at this time.

(This

matter was discussed at the management exit).

Surveillance of the Auxiliary Feedpump Room~/ ]_/

The licensee has established a required inspection each shift

of the auxiliary feed pump room based on the previous inspec-

t ion findings.

This item will remain open pending completion

of the review by IE.

(This matter was discussed at the manage-

ment exit.)

Plant Procedures~/

The inspector reviewed the status of certain plant procedure

revisions which were deemed necessary following certain plant

events (The matter was discussed at the management exit).

(1)

Plant cooldown without primary coolant pumps available.

The licensee is preparing a procedure for boration and

cooldown with a total loss of offsite power.

IE Inspection Report No. 50-255/78-08.

IE inspection Report No. 50-255/78-13.

Ibid.

IE Inspection Report No. 50-255/78-22.

IE Inspection Report No. 50-255/ 77-14.

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(2)

Loss of feedwater systems.

The licensee is preparing a

procedure for removal of decay heat from the reactor

core via the steam generators utilizing the available

water sources, including auxiliary feedwater, condensate,

and fire protection water.

This matter will remain open pending completion of the procedures

by the licensee.

9.

Reportable Events

The inspectors reviewed the licensee's actions concerning the

following nonroutine event reports to verify the events were

reviewed and evaluated, corrective actions taken, and plant limits

not exceeded.

The review included selected PRC minutes, records,

and personnel interviews.

a.

LER 78-23, Stearn Generator Tube Differential Pressure of

1380 psi.

An independent review of the event and the licensees

evaluation has been conducted by RIII.

No further questions

are required of this matter at this time and this item is

considered closed.

b.

LER 78-31, CRDM-39 Inoperable.

~

No items of noncompliance or deviations were identified.

10.

Management Exit Interview

a.

Corporate Office

A management exit interview (attended as noted in paragraph l.a)

was conducted in the licensee's corporate office on October 18,

1978.

The inspector identified the areas inspected (quality

assurance and review/audit items) and sununarized the findings.

Two items of noncompliance identified in the area of technical

audits (paragraph 4) were specifically discussed.

b.

Palisades Nuclear Plant

A management exit interview (attended as noted in paragraph l.b)

was conducted at the plant following completion of the inspec-

tion on October 20, 1978.

The following items were discussed,

with licensee responses as noted:

(1)

The inspectors sununarized the scope and findings, including

identified noncompliances, for the portion of the inspection

conducted at the licensee's corporate offices.

(Paragraphs

4 and 5)

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.l

'

( *

(2)

The licensee acknowledged the inspectors' remarks con-

cerning lack of routine testing of the fixed thermal

and magnetic trip devices in the 480 volt AC electrical

equipment.

The inspectors noted this matter would be

reviewed further by IE.

(Paragraph 5)

(3)

The inspectors stated and the licensee acknowledged the

apparent item of noncompliance relating to the "block"

of safeguards system automatic actuation outside procedural

controls.

(Paragraph 3.c)

(4)

The inspectors stated the apparent item of noncompliance

concerning failure to perform shiftwise comparison checks

of secondary rod position indications against primary

position indication.

The licensee noted the deviation

alarm for single-rod drift had remained available and

that all rods except those in group 4 (controlling) were

maintained at their upper electrical limit.

(Paragraph 3.d)

(5)

Boric acid heat tracing system problems were discussed.

The licensee stated plans are being made to modify and/or

replace the heat tracing system during the next refueling

outage, and that boric acid line, tank and pump tempera-

tures would be maintained during the interim period.

(Paragraph 3. c)

(6)

The inspector stated the apparent item of noncompliance

with 10 CFR 50 Appendix B relating to procurement of

safety-related components and equipment.

(Paragraph 6)

(7)

The inspectors discussed items noted during inspection

of plant stores, including pipe capping, eves filter

protection, and weld rod moisture protection.

The

licensee indicated positive means of assuring continuous

weld rod protection would be considered.

(Paragraph 6)

(8)

The licensee stated preparation of procedures for cool-

down without primary coolant pumps and for loss of

feedwater (pursuant to previous commitments) was nearly

complete.

(Paragraph 8.d)

(9)

The licensee stated valves in the fire protection supply

to the auxiliary feedwater pump suction had been added

to hisSection XI checklist (inservice inspection program)

and the flow path would be verified.

(Paragraph 8.b)

(10)

The licensee stated shiftwise auxiliary feedwater (AFW)

pump room surveillance had been established and was

being documented.

Further, installation of a level alarm

to detect AFW pump room flooding will be considered.

(Paragraph 8.c)

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