ML18046A264
| ML18046A264 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/31/1980 |
| From: | Boyd D, James Heller, Jorgenson B, Peschel J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18046A265 | List: |
| References | |
| 50-255-80-18, NUDOCS 8012310433 | |
| Download: ML18046A264 (9) | |
See also: IR 05000255/1980018
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/80-18
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackosn, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
License No. DPR-20
Inspection Conducted:
September 1-5, 8-12, 15-19, 21-27, 29, 30,
and October 1-3, 1980
Inspectors:
f
Approved By:
B. L.
~a.P.1\\_,4-
Jorgefis~ri(_J CJ~
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D. C. Boyd, C~f,-
Reactor Projects, Section 4
Inspection Summary
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Inspection on September 1-5, 8-12, 15-19, 21-27, 29, 30 and October 1-3,
1980 (Report No. 50-255/80-18)
Areas Inspected:
Routine monthly resident inspection program activities
including; operational safety; maintenance; surveillance; facility changes;
procedures; plant trip; current regulatory items; followup on previously
identified items; and operator strike.
The inspection involved a total of
247 inspector-hours onsite by three NRC inspectors including 24 inspector-
hours onsite during off-shifts.
Results:
No items of noncompliance or deviations were identified in any
of the eight areas inspected.
1.
DETAILS
Persons Contacted
- R. W. Montross, General Manager
- J. S. Rang, Operations and Maintenance Superintendent
- H. J. Palmer, Technical Superintendent
W. S. Skibitsky, Operations Superintendent
- C. H. Gilmor, Maintenance Superintendent
B. L. Schaner, Operations Supervisor
K. M. Farr, Public Affairs Director
G. H. R. Petitjean, Technical Engineer
F. G. Butler, Senior Engineer
G. D. Gilbody, Quality Assurance Engineer
D. W. Kaupa, Shift Supervisor
W. Hodge, Property Protection Superintendent
Other members of the operations, maintenance and technical staffs
were also contacted briefly,
- Denotes those present at management* interview October 3, 1980.
2.
Operational Safety Verification
The inspector observed control room operations, reviewed applicable
logs and conducted discussions with control room operators during the
month of September 1980.
The inspector verified the operability of
selected emergency systems, reviewed tagout records, and verified
proper return to service of affected components.
Tours of auxiliary
and turbine buildings were conducted to observe plant equipment condi-
tions, including potential fire hazards, fluid leaks, and excessive
vibrations and to verify that maintenance requests had been initiated
for equipment in need of maintenance.
The inspector by observation
and direct interview verified that the physical security plan was being
implemented in accordance with the station security plan.
The insepctor observed plant housekeeping/cleanliness conditions and
verified implementation of radiation protection controls.
During the
month of September 1980, the inspector walked down the accessible
portions of the auxi~iary feedwater and safety injection systems to
verify operability.
Minor housekeeping items were brought to the attention of the duty
Shift Supervisor for his action, as appropriate.
One item, involving the apparent malfunctioning of the closure mech-
anism on a door designated a plant fire barrier, was brought to the
attention of the fire protection specialist.
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During walkdown of the auxiliary feedwater system using Feedwater
System Checklist CL 12.1, the Resident Inspector found valve 709 WS
had been changed as a result of a recent facility modification.
The
valve presently serves as an instrument isolation valve for auxiliary
feedwater suction header pressure instrumentation added by the refer-
enced modification.
Previously, the valve had served as a header vent
valve.
Thus, the proper operational condition for the valve is the open
position.
The valve was correctly positioned, and the checklist was
erroneous.
Review of the latest completed CL 12.1, performed in May 1980, shows
the auxiliary operator identified the proper position of the valve as
"open" and made a pen-and-ink change to the checklist; but a temporary
or permanent change was not subsequently made to follow up on the
operator's action.
This was discussed with the Operations Superintendent,
who committed to correct CL 12.1, and who stated problems of this type
had been previously recognized and were the basis for recent revisions
to the plant Administrative Procedures pertaining to checklists.
These
procedures now provide a method for handling checklist vs actual posi-
tion discrepancies which were reviewed by the inspectors and considered
adequate.
Thus, means are developed to correct checklist deficiencies
which may result from a modification to the facility such that a valve,
breaker, or other control acquires a changed service condition.
Means
to prevent such deficiencies by revising checklists and procedures at
the time of facility modification were also reviewed.
This area is not
now clearly controlled; which probably contributed to the inaccuracy
of CL 12.1 above.
This matter was discussed at the management interview.
The inspector also noted during walkdown of CL 12.1 that the auxiliary
feedwater pump suction valve from the condensate storage tank (133 FW),
which is located in a pit in the plant yard adjacent to the tank, was
under water.
This is properly identified on the checklist as a "locked-
open" valve, but the valve position could not be verified.
The licensee,
by letter dated December 11, 1979, in response to an NRC letter dated
October 30, 1979, concerning "Requirements for Auxiliary Feedwater Systems
at Palisades," committed to lock open valves in series with the auxiliary
feedwater pumps' section (which includes valve 133 FW) and to verify
monthly that such valves are in fact locked open.
Discussion with licensee
staff indicated the valve pit may be frequently flooded depending on local
weather, particularly heavy rainfall. It is unclear how the required
monthly valve position verification is made if the valve is submerged.
This was discussed at the management interview.
The inspector also witnessed portions of the radioactive waste system
controls associated with overpack of Urea Formaldehyde solidified waste,
barreling, and radwaste shipments .
- 3 -
These reviews and observations were conducted to verify that facility
operations were in conformance with the requirements established
under Technical Specifications 10 CFR and administrative procedures.
No items of noncompliance or deviations were identified.
3.
Monthly Maintenance Observation
Station maintenance activities of safety related systems and components
listed below were observed/reviewed to ascertain that they were con-
ducted in accordance with approved procedures, regulatory guides and
industry codes or standards and in conformance with Technical Speci-
cations.
The following items were considered during this review; the limiting
conditions for operation were met while components or systems were
removed from service; approvals were obtained prior to initiating the
work; activities were accomplished using approved procedures and were
inspected as applicable; functional testing and/or calibrations were
performed prior to returning components or systems to service; quality
control records were maintained; activities were accomplished by quali-
fied personnel; parts and materials used were properly certified; radio-
logical controls were implemented; and, fire prevention controls were
implemented.
Work requests were reviewed to determine status of outstanding jobs
and to assure that priority is assigned to safety related equipment
maintenance which may affect system performance.
The following maintenance activities were observed/reviewed:
safety-related snubbers-hydraulic oil addition
emergency diesel-motor preventive maintenance
Following completion of maintenance on the 1-1 emergency diesel-
generator and hyrdaulic snubbers noted above, the inspector verified
that these systems had been returned to service properly.
No items of noncompliance or deviations were identified.
4.
Monthly Surveillance Observation
The inspector observed Technical Specifications required surveillance
testing on the "B" boric acid pump, the low-pressure safety injection
(LPSI) pumps, and on selected snubbers, and verified that testing was
performed in accordance with adequate procedures, that test instru-
mentation was calibrated, that limiting conditions for operation were
met, that removal and restoration of the affected components were
accomplished, that test results conformed with Technical Specifications
and procedure requirements and were reviewed by personnel other than
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L
the individual directing the test, and that any deficiencies identified
during the testing were properly reviewed and resolved by appropriate
management personnel.
Problems were encountered in conduct of surveillance testing on the
LPSI pumps on September 18 and 19 in that the results seemed to
indicate precisely parallel miniflow rate degradation on both pumps.
The common* flow instrument (FI-0404) was not seriously considered
suspect in that it had given expected and consistent results on
testing of the containment spray pumps, showing no degradation.
Inadequate pump isolation, to assure only the miniflow path was
available, was theorized, in that the respective pump discharge
isolation valves were known to leak when closed.
Ultimately, the
test procedure was revised to base operability determination on pump
delta-pressure rather than flowrate via the miniflow path.
Results
from testing by the revised procedure were consistent with baseline
data and showed pump performance not degraded.
Flow data are still
being taken in an attempt to determine why miniflow is decreasing.
No items of noncompliance or deviations were identified.
5.
Facility Change
Selected facility modifications/design changes were reviewed during
this inspection to verify proper review and approval (including
adherence to the requirements of 10 CFR 50.59); to verify installa-
tion in accordance with the approved design; and to verify completion
of appropriate testing and revisions to procedures and drawings.
Identification and use of codes and standards governing modification
work was examined, as were acceptance testing and overall record-
keeping.
The following packages were specifically examined.
FC 468-5 -
FC *379B -
Change of power supply for containment pressure
instrumentation to a Class I-E source
Overhaul and "beefing-up" of MSIV internals
A potential problem relating to procedure and checklist revision as a
result of facility modifications is discussed in Paragraph 2, above.
No items of noncompliance or deviations were identified.
6.
Procedures
Several licensee procedures were examined during this inspection to
determine technical adequacy; consistency to license requirements;
and proper development, review, approval and revision.
The following categories and procedures were specifically reviewed
during this inspection:
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a .
General Plant Operating Procedures (GOP's)
(1)
GOP-2
(2)
GOP-8
Plant Heat Up (cold shutdown to hot
standby)
Plant Shutdown to Hot Standby/shutdown
b.
System Operating Procedures (SOP's)
c.
d.
e.
f.
(1)
SOP-1
Primary Coolant System
(2)
SOP-7
Main Steam System
(3)
SOP-16
Component Cooling Water System
(4)
SOP-15
Service Water System
(5)
SOP-19
Service and Instrument Air System
(6)
SOP-36
Reactor Protective System
Step 6.1.1.1 of SOP-1 references primary coolant system checklist
CL 1.1.
A copy of CLl.l was found in the shift supervisor's
check list file, which is a "controlled" file, lacking an approval
signature or initials on page 5 of 13, as apparently required by
administrative procedure 10-1, Appendix C-4.
This was identified
to the licensee for review and correction.
Off Normal Procedures (ONP's)
(1)
ONP-1
Loss of Load
(2)
ONP-5
Control Rod Drop
(3)
ONP-12
Acts of Nature
(4)
OPN-14
(5)
ONP-17
Loss of Shutdown Cooling
(6)
ONP-23
Primary Coolant Leak
Permanent Maintenance Procedures
(1)
Procedure No. PCS-M-1
(2)
Procedure No. CCS-M-1
(3)
Procedure No. MSS-M-1
(4)
Procedure No. SWS-M-1
(5)
Procedure No. RPS-I-2
Emergenc~ 0Eerating Procedures (EOP' s)
(1)
(2)
Loss of Instrument Air
(3)
Loss of Coolant Accident
(4)
Loss of Containment Integrity
Administrative Procedures
(1)
Operations Administration
(2)
Plant Security
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A review was also conducted covering review and approval of procedure
revisions and associated recordkeeping.
Plant Administrative Proce-
dures, Section 3, addresses these matters, providing for review via a
PRC/QA review form (QA-05).
The QA-05 form, supporting documents and
Safety Evaluations are to be maintained in a "QA-5 file".
The licensee's
QA-05 file, however, has not been maintained since 1978.
Rather, the
review records are being kept with the Plant Review Committed (PRC)
meeting minutes.
This was discussed at the management interview.
The licensee's Administrative Procedures, Section 3, and 10 CFR 50.59,
do not differentiate handling of procedure revisions from facility
modifications or from tests and experiments insofar as the review pro-
cess and recordkeeping are concerned.
In practice, the licensee utilizes
a Safety Evaluation form in review of facility modifications and tests/
experiments but not in review of procedure revisions.
This Safety
Evaluation provides details concerning why a review item does or does
not involve an unreviewed safety question as defined in 10 CFR 50.59.
The QA-05 form, which is used in all cases, provides simply for a Y (yes)
or N (no) determination by the reviewer concerning identification of
unreviewed safety questions, without addressing why.
A further requirement
of 10 CFR 50.59 involves maintaining records of selected reviews (including
certain procedure changes), to include a written safety evaluation which
provides the basis for the determination that the change in question does
not involve an unreviewed safety question.
It is not clear that the QA-05
review alone is adequate for this purpose, and licensee compliance to
10 CFR 50.59 for review and recordkeeping relating to selected procedure
changes is considered an Unresolved Item.
This matter will be reviewed
further during a future inspection; and it was discussed at the Management
interview.
No items of noncompliance or deviations were identified.
7.
Plant Trip
Following the plant trip at 0238 hours0.00275 days <br />0.0661 hours <br />3.935185e-4 weeks <br />9.0559e-5 months <br /> on September 28, 1980, the
inspector was contacted by the licensee.
He ascertained the status
of the reactor and safety systems by discussions with plant personnel
and verified proper .communications and immediate licensee actions.
The reactor and turbine were manually tripped from about 82% power
immediately after a DC electrical ground caused an erroneous speed
control signal which led to the sudden closure of all the turbine
intercept valves.
All plant systems responded as designed, and the
plant was returned to operation, later the same day following repair
of the faulty electrical condition.
No items of noncompliance or deviations were identified.
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, *
8.
Current Regulatory Matters
Licensee adherence to the stipulations of two Immediate Action Letters,
both involving auxiliary feedwater flowrates as they affect steam
generator level and avoidance of water hammer, was verified during
this inspection.
The first IAL, dated August 26, 1980 also provided
a 55% maximum power level, which was observed by the licensee and
verified by the inspector.
The second IAL, dated September 4, 1980,
superceded the first and provided an 83% maximum power level.
This
was also observed by the licensee as verified by the inspector.
Power level restrictions were removed by an NRC letter effective
September 30, 1980.
Selected procedure changes and operator training
related to removal of power level restrictions were completed as
required and reviewed by the inspector.
The licensee will continue
an evaluation of means to mitigate or eliminate the potential for
water hammer and provide the evaluation results and plans for future
NRC review.
No items of noncompliance or deviations were identified.
9.
Action on Previously Identified Matters
(Closed) Unresolved Item, IE Inspection Report No. 50-255/79-07
Inservice testing acceptance criteria for ESF pumps.
The licensee has requested and received NRC approval for
modification of Technical Specifications to incorporate ASME
Section XI; in part; and certain exemptions/exceptions have
also been approved.
The licensee is not required to use both
flow and delta-pressure measurements in determining operability
of ESF pumps .
10.
Operator Strike
On September 12, 1980, a "wildcat strike" involving plant operations,
maintenance, and construction personnel occurred; lasting slightly
over two hours after the scheduled 0800 hour0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> shift-change.
The
inspector verified proper shift staffing, which was maintained by
holding-over the off-going shift.
Licensee contingency plans for
coping with a potentially longer-duration strike were also reviewed.
No items of noncompliance or deviations were identified.
11.
Unresolved Items
Unresolved items are items for which additional information is required
to make a determination whether the item is a clear item, an item of
noncompliance, or a deviation.
An unresolved item identified during
the course of this inspection is discussed in Paragraph 2 above .
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12.
Management Interview
A management interview (attended as indicated in Paragraph 1) was
conducted following completion of the inspection.
The following
items were discussed with licensee responses as indicated.
a.
The inspectors summarized the scope and findings of the inspection.
b.
Proper followup on procedures and checklists, to complete revisions
required as a result of facility modifications, was discussed.
(Paragraph 2)
c.
The inspectors questioned the means by which the position of an
occasionally submerged valve had been and will be verified.
The
licensee agreed to look into the matter.
(Paragraph 2)
d.
The testing evolution and problems experienced in verifying LPSI
pump operability were discussed.
(Paragraph 4)
e.
The inspector identified the apparent inconsistency between
practice and procedure as related to the keeping of a "QA05
file." The licensee agreed to clarify this.
(Paragraph 6)
f.
The inspectors stated the Unresolved Item relating to record-
keeping under 10 CFR 50.59.
The licensee pointed out the QA-05
definition of "unreviewed safety questions" printed thereon, for
use in making reviews involving this determination.
(Paragraph 6)
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