ML18043A824
| ML18043A824 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/17/1979 |
| From: | Jorgensen B, Warnick R, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18043A823 | List: |
| References | |
| 50-255-79-07, 50-255-79-7, NUDOCS 7907180411 | |
| Download: ML18043A824 (10) | |
See also: IR 05000255/1979007
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/79-07
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
Inspection Conducted:
April 30-May 4 and May 9-11, 1979
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Inspectors: {""" B. L. Jorgensea_)
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r1'- G. C. Wright
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Approved Byi~R. F. Warnick, Chief
Reactor Projects Section 2
Inspection Summary
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Inspection on April 30-May 4 and May 9-11, 1979 (Report No.
50-255/79-07)
Areas Inspected:
Special, announced inspection of licensee activ-
ities in response to IE Bulletin 79-06B including operability and
availability of engineered safety features (ESF); administrative
control of ESF; ESF status at the time of inspection; operator
training; operating procedures; and licensee response to other
miscellaneous Bulletin items.
The inspection involved 122
inspector-hours onsite by two NRC inspectors.
Results:
No items of noncompliance or deviations were identified in
any of the areas inspected.
One unresolved item was identified
(Paragraph 4) relating to the necessity of obtaining both flowrate
and discharge pressure on inservice inspection of ESF pumps .
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1.
DETAILS
Persons Contacted
- J. Lewis, Plant Superintendent
- H. Keiser, Operations and Maintenance Superintendent
- K. Berry, Technical Superintendent
- R. McCaleb, Quality Assurance Superintendent
- B. Shaner, Operations Supervisor
- B. Harshe, Senior Engineer
- G. Petitjean, General Engineer
- R. Mieras, Shift Supervisor
- D. Langschwager, Shift Supervisor
A. Brookhouse, Shift Supervisor
S. Ghidotti, Shift Supervisor
W. Thompson, Shift Supervisor
D. Kaupa, Shift Supervisor
K. Villermain, Control Operator
G. Cheeseman, Control Operator I
J. Ford, Control Operator I
G. Pothoff, Control Operator II
W. Stearns, Control Operator II
J. Liddell, Training Supervisor
C. Bills, Engineering Analyst
Some discussions were also held with eight additional oper-
ations staff personnel; control operators and auxiliary
operators.
- present at inspection status meeting on May 4, 1979.
- present at May 4 status meeting and at final exit inter-
view May 11, 1979.
2.
General
This inspection was conducted to review licensee activities in
response to IE Bulletin 79-06B "Review of Operational Errors
and System Misalignments Identified During the Three Mile
Island Incident." This review included verification of licensee
activities as identified in his initial written response to the
Bulletin and examination of other related activities.
This inspection also included an independent review by the
inspectors of records, procedures and equipment to determine
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3.
the continuous availability and operability of safety-related
systems and components as required.
During this inspection, direct training discussions were con-
ducted on May 2, 1979, with six members of the Palisades Plant
operating staff concerning the sequence of events at the Three
Mile Island Nuclear Station Unit 2 during and following the
loss of feedwater incident on March 28, 1979.
Sections of IE
Bulletin 79-06B were also discussed.
These training discussions
were provided for operating staff personnel not present during
previous presentations by an IE and NRR task group on April 19,
1979.
Thus, as of May 2, 1979, every member of the plant operating
staff had attended a direct training discussion on these subjects
provided by NRC.
Engineered Safety Features Availability/Operability
This inspection included a review of engineered safety systems
alignment procedures against current piping and instrument
diagrams and single-line diagrams to verify the alignments do
not compromise the availability or operability of safety-related
components.
Valve, breaker, and/or switch alignments were
examined for the following systems:
a.
High Pressure Safety Injection
b.
Low Pressure Safety Injection
c.
Charging Pumps
d.
Component Cooling Water
e.
f.
Service Water (emergency services portions)
g.
Containment Isolation Systems
h.
i.
Safety Injection Tanks
j.
k.
Containment Fan Coolers
The reactor protection and safeguards actuation circuitry were
also reviewed briefly, as were portions of the primary coolant
system.
Lineups are provided, for the most part, by checklist.
The
same checklist for proper lineup may be referenced by various
procedures.
Where checklists were so referenced, they were
utilized for the inspection.
For some operations surveillance
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tests, return-to-service lineups are specified within the test
procedure.
All such lineups were also examined to verify
systems are properly returned to an operable condition.
The review of system lineup and surveillance test procedures
did not identify any instances of improper lineup control, such
that the operability or availability of safety systems would be
compromised.
A number of inconsistencies, contradictory or
confusing instructions, apparent typographical errors and
outdated references were noted.
None of these were considered
significant from the standpoint of affecting safety-related
systems, but a compilation of such items was provided to the
licensee for his followup.
Licensee activities in performance of the same type of system
operability and availability review were examined during this
inspection and discussions were held with cognizant licensee
personnel.
The licensee has concentrated on valve lineups
specified by procedure or checklist, and has included deter-
minations that lineup control is complete and that valve
failure modes do not compromise engineered safety features
operation.
By May 11, 1979, only the review of the emergency
services portions of the service water system remained to be
completed.
Licensee personnel stated no items had been iden-
tified which could compromise the operability or availability
of required engineered safety features.
No items of noncompliance or deviations were identified.
4.
Engineered Safety Features Administrative Control
Licensee administrative controls to assure proper return to
service of safety-related systems and components following
maintenance activities and at the conclusion of extended
outages are and have been subject to continuing review by the
NRC inspector.
These areas were reviewed during this inspec-
tion only to ascertain management controls have not been changed
so as to reduce their effectiveness.
Based on this determination,
administrative controls continue to be considered adequate to
assure proper return to service.
Discussions were also conducted with licensee personnel con-
cerning independent verification of system lineups.
The
licensee utilizes independent verification of component oper-
ability and valve positioning prior to return to power oper-
ations from any cold shutdown, in accordance with plant
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procedures.
This constitutes a verification by licensed per-
sonnel of proper return to service by maintenance personnel
and/or auxiliary operators.
Additional independent verifi-
cation is occasionally performed by duty shift supervisors in
accordance with other selected procedures, at the direction of
the Operations Supervisor, or at the shift supervisor's own
initiative.
Licensee tagging practice and procedures, to provide control
operator cognizance of equipment status, was reviewed during
control room tours conducted during this inspection.
The
purpose of this review was to ascertain the potential for tags
to obscure position indicators, meters or alarms.
Plant oper-
ators may use either of two types of tags in the control room;
one a small adhesive sticker and the other a larger hanging
tag.
Discussions with operating staff and examination of tags
currently in place indicate very little liklihood that meters
or alarms have been or will be obscured.
A few hanging tags
were noted, however, primarily on vertical panels, which were
at least partially obscuring various indicator lights.
None of
these involved safety-related equipment.
Results of the most recent surveillance testing of safety-related
components were examined during this inspection to verify
conformance to acceptance criteria. Technical Specification 4.6.3 describes acceptable pump performance as achieving rated
shutoff head at minimum recirculation flow.
This implies both
pump discharge pressure and flowrate must be verified.
The
Palisades Nuclear Generating Plant does not have and has never
had instrumentation installed to provide containment spray pump
discharge pressure indication. Further, though flow instrumen-
tation is available and is used for the testing of high-pressure
and low-pressure safety injection pumps, no acceptance criteria
for pump flowrate have been established.
This matter will be
brought to the attention of the NRC Off ice of Nuclear Reactor
Regulation for a determination on the adequacy of current
practice. Until such determination, this item will be considered
an unresolved item.
No items of noncompliance or deviations were identified.
S.
Current Engineered Safety Features Status
During this inspection licensee valve lineup procedures and
current piping and instrument diagrams were also used in a
comparison against actual conditions (plant in cold shut-down)
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and against required positions for power operations as verified
by physical inspection of all accessible components in engineered
safety systems.
Complete system flowpath walkdowns, except
inside the containment building, were completed for the following:
a.
High Pressure Safety Injection
b.
Low Pressure Safety Injection
c.
Component Cooling Water (emergency services portions)
d.
Service Water (emergency services portions)
e.
f.
Extensive walkdowns, limited slightly by accessibility con-
siderations, were also performed on the charging and concen-
trated boric acid systems.
Among those systems aligned as they would be as required for
power operations, no valves were identified as mis-positioned.
Positive position control was questionable on three valves,
which were identified to the licensee for his followup.
Three
instances were noted in which the current piping and instrument
diagram did not reflect the "as built" configuration correctly.
These were also identified to the licensee.
None of the iden-
tified inconsistencies were considered to threaten availability
or operability of required systems, though one item requires
further review.
This item concerns the fact that the service
water return isolation valve from the containment fan coolers
(CV-0824) has been relocated significantly from its original
position near the containment penetration in the component
cooling water pump room.
The valve is now located an estimated
50 feet from its original position, downstream of a flow instru-
ment, in the west .safeguards room.
Although it is believed the
valve was relocated as many as 8 to 10 years ago, neither
system checklists nor current drawings reflect the correct
valve location.
Several members of the operations staff,
including the last individual documented to have checked this
valve, were questioned, with each person indicating a belief
the valve is located in the CCW pump room.
The licensee stated
a review would be performed to determine the affect, if any, of
the repositioning of valve CV-0824 on system function.
This
review will specifically include a verification that the seismic
qualification of the involved piping runs is not compromised.
This item will be reviewed during a subsequent inspection .
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Normal and standby power supplies for safeguards components in
the above systems were also examined during this inspection.
This examination included the 2400v. safeguards buses 1-C and
1-D; 480v. load centers 11 and 12; 480v. motor control centers
1, 2, 7 and 8; and 120v. preferred a.c. buses Y-10, Y-20, Y-30
and Y-40 including chargers, battery banks, and inverters.
During this review, charging pump P-55C was determined to be
the available pump, while the "Safeguards Equipment Status"
board in the control room erroneously indicated P-55A to be the
available pump.
The status board was immediately corrected.
It was noted the power supply indications on the control panel
were correct.
Particular attention was directed to the examination of valve
and switch or breaker positions for the auxiliary feedwater
system.
The walkdown of this system on May 3, 1979, included a
verification that all valves identified by the licensee as
requiring positive position control were actually locked in the
required position.
No items of noncompliance or deviations were identified.
6.
Operations Staff Training
Licensee activities to provide an appropriate review of the
loss of feedwater incident at Three Mile Island Unit 2 for his
operations staff personnel were examined during this inspection.
This effort has taken three forms as follows:
a.
An early, undocumented review focused on conditions leading
to fuel damage and offsite releases of radioactivity.
b.
Operations Department memoranda addressing reset of SIS,
maintenance of 50°F subcooling, and the licensee's written
response to IE Bulletin 79-06B.
c.
A longer term incorporation of TMI-related considerations
as they affect operating practice at Palisades, into the
routine formal operator requalification training program.
At the time of this inspection considerable effort had been
expended in reviewing the TMI incident as it might relate to
the Palisades nuclear plant.
Though not yet well documented,
interviews with training staff and with plant operations staff
indicate the discussions have been comprehensive with respect
to items identified for review in IE Bulletin 79-06B.
Further
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discussions and training, for which documentation will be more
extensive, are planned for the 5-week training cycle beginning
May 21, 1979.
No items of noncompliance or deviations were identified.
7.
Operating Procedures Review
Licensee review of operating, off-normal and emergency pro-
cedures pursuant to matters identified in IE Bulletin 79-06B
was discussed with licensee personnel during this inspection.
These activities have been as described in the licensee's
response to the subject Bulletin dated April 27, 1979.
Specific attention was directed to manual initiation of
auxiliary feedwater since this system is not automatically
initiated at Palisades.
Discussions were_ held with plant
operators and data derived from plant trips from high power
level were reviewed.
Manual initiation is a relatively simple
evolution, in which plant operators are well experienced,
normally accomplished from the control room but with backup
control locally in the plant.
The discussions and review
indicate auxiliary feedwater can be and has been established
within seconds.
This is seldom necessary, however, since one
of two main feedpumps usually remains available.
These pumps
do not trip on reactor or turbine trip but instead ramp down to
5% output in 60 seconds.
It was determined the licensee does not have procedures pre-
pared for feeding a dry steam generator.
In fact, existing
procedures caution against such unless absolutely necessary.
The Palisades Plant steam generators are sized such as to
provide about 16 minutes of decay heat removal after loss of
all feedwater from full power.
Other procedure revisions contemplated, relating to continuance
of forced circulation flow and HPSI flow, had not been made at
the time of the inspection.
Some modification of plant systems
will be required to enable such operation for those cases where
the conditions initiating SIS clear almost immediately or the
SIS is otherwise unnecessary.
No items of noncompliance or deviations were identified .
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8.
Other Bulletin Items
Two additional items from IE Bulletin 79-06B, relating to
isolation of containment on SIS and to assuring the pressurizer
power-operated relief valves do not malfunction, were reviewed
and discussed during this inspection.
As noted in the licensee's submittal of April 27, 1979, the SIS
signal at Palisades performs some isolation functions but not a
complete containment isolation.
However, there may be little
or no benefit from complete isolation on SIS, considering plant
design and operating requirements, and the effect of a complete
isolation on continued availability of the primary coolant
pumps may be deleterious.
The licensee has no plans to modify
the existing containment isolation signals to include SIS.
The pressurizer power-operated relief valves (PORV's) at
Palisades are isolated during normal power operations, being
used only to provide overpressure protection below 300°F
primary coolant system temperature.
The several indications
that a PORV is open have been identified to plant operators.
No items of noncompliance or deviations were identified.
9.
Unresolved Items
Unresolved items are items about which more information is
required in order to ascertain whether they are acceptable
items, items of noncompliance, or deviations.
An unresolved
item disclosed during the inspection is discussed in Paragraph
4.
10.
Management Interviews
Management interviews (attended as shown in Paragraph 1) were
conducted on May 4, 1979, and at the conclusion of the inspec-
tion on May 11, 1979.
The inspectors discussed the scope and
findings of the inspection.
The following were specifically
discussed, with licensee responses as noted.
a.
The inspectors advised the licensee that the independent
review of ESF systems, lineups and administrative controls
performed by the inspectors had identified no conditions
threatening ESF operability or availability .
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b.
The inspectors stated the unresolved item relating to
surveillance testing acceptability criteria for ESF pumps.
The licensee stated submittals for change of the existing
technical specifications had been made, requesting confor-
mance to ASME Section 11 on inservice inspection.
The
licensee further noted ASME Section 11 does not require
acceptance criteria for both pump flowrate and discharge
pressure.
c.
Summary notes relating to inconsistencies, dated references,
apparent inaccuracies and other comments from the inspectors'
reviews were provided to the licensee.
d.
Modification of the Palisades Plant as may be considered
appropriate in view of IE Bulletin 79-06B was discussed.
The inspectors stressed the necessity, and the licensee
concurred, that very careful evaluation precede any modi-
fication with the potential to affect safety-related
systems, no matter the time frame.
e.
The relocation of valve CV-0824 (service water return
isolation from the containment fan coolers) was discussed.
The licensee stated the effect of the repositioning, if
any, would be evaluated, including verification that the
seismic qualification of the piping run is not compromised .
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