ML18046A832

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IE Insp Rept 50-255/81-10 on 810601-06,08-13,15-20 & 22-0703.Noncompliance Noted:Failure to Follow Required Procedures for Surveillance & Testing of safety-related Equipment
ML18046A832
Person / Time
Site: Palisades Entergy icon.png
Issue date: 07/16/1981
From: Boyd D, James Heller, Jorgensen B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18046A830 List:
References
50-255-81-10, NUDOCS 8108030258
Download: ML18046A832 (9)


See also: IR 05000255/1981010

Text

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-255/81-10

Docket No. 50-255

Licensee:

Consumers Power Company

212 West Michigan Avenue

Jackson, MI

49201

Facility Name:

Palisades Nuclear Generating Plant

Inspection At:

Covert, MI

License No. DPR-20

Inspection Conducted:

June 1-6, 8-13, 15-20 and June 22 - July 3, 1981

Inspectors: r

~/#~~

B. L. Jorgensen

  1. ~~

/b"- J. K. Heller""'j

D.C.B~1

7-/t;;.--81

7-16-81

Approved By:

7- /~ - rt"/

Reactor Projects Section lA

Inspection Summary

Inspection during June, 1981 (Report No. 50-255/81-10)

Areas Inspected:

Augmented resident inspection program including:

operational safety; maintenance; surveillance; reportable events;

followup on IE Circulars and previous noncompliance; final review on

spent fuel rack replacement; and miscellaneous plant activity review.

The inspection involved 226 inspection-hours onsite by two NRC in-

spectors, including 93 off-shift inspection hours.

Results:

Of the eight areas examined, no items of noncompliance or

deviations were identified in seven areas.

One noncompliance (Severity

Category V - failure to follow procedures as required) was identified in

the remaining area.

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, PDR ADOCK 05000255

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1.

DETAILS

Persons Contacted

  • R. W. Montross, General Manager

J. S. Rang, Operations/Maintenance Superintendent

  • H. J. Palmer, Technical Superintendent

G. H. R. Petitjean, Technical Engineer

  • J. L. Corley, General Supervisor of Quality Operations

R. E. McCaleb, Quality Assurance Administrator

W. P. Mullins, Plant Health Physicist

W. S. Skibitsky, Operations Superintendent

W. E. Adams, Senior Engineer (STA)

G. W. Ford, Senior Engineer (STA)

W. L. Burmeister, Shift Technical Advisor

A. F. Brookhouse, Shift Supervisor

S. Ghidotti, Shift Supervisor

A. S. Kanicki, Shift Supervisor

D. W. Kaupa, Shift Supervisor

R. E. Mieras, Shift Supervisor

E. I. Thompson, Shift Supervisor

C. H. Gilmor, Maintenance Superintendent

S. F. Pierce, Radioactive Materials Control Supervisor

W. M. Hodge, Property Protection Superintendent

K. M. Farr, Public Affairs Director

W. E. Adams, Senior Engineer (STA)

W. P. Mullins, Plant Health Physicist

R. L. Muzzi, Associate Engineer

  • Denotes those present at Management Interview on July 3, 1981.

Numerous other members of the plant Operations/Maintenance, Technical,

and Chemistry/Health Physics staff were also contacted briefly.

2.

Operational Safety Verification

The inspector observed control room operations reviewed applicable

logs and conducted discussions with control room operators during the

month of June, 1981.

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

conditions, 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 .

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The inspector observed plant housekeeping/cleanliness conditions and

verified implementation of radiation protection controls.

During

the month of June, 1981, the inspector walked down the accessible

portions of the iodine removal and diesel generator systems to

verify operability.

During walkdown of the iodine removal system

using Iodine Removal Instrumentation checklist 3.7, the Resident

Inspector found three valves closed which the checklist stipulates

to be in the open position.

Discussion with the Shift Supervisor

established the valves are properly positioned per the alarm response

procedure for high nitrogen pressure to system tanks T-103 and T-102.

The valves are required to be shut until plant conditions permit

repairs to the nitrogen pressure control valves for these tanks.

While cross checking checklist 3.7 against drawing M-204, the in-

spector observed that the print listed valve 3357 ESS twice, once as

N2 to T-102 and once as T-102 drain.

This item was brought to the

aEtention of the appropriate supervisor.

The inspector also witnessed portions of the radioactive waste system

controls associated with radwaste shipments and barreling.

A radwaste

truck awaiting shipment was independently surveyed on June 23, 1981.

This inspection included review of licensee actions under the

provisions of an NRC Generic Order dated April 20, 1981.

The

purpose of this order is to ensure the low probability of High

Pressure Safety Injection (HPSI) and Low Pressure Safety Injection

(LPSI) check valve failures which could result in an inter system

loss of coolant accident.

Until the plant is modified to permit

testing of the HPSI and LPSI checkvalves, the licensee has taken the

following actions to comply with the order requirements.

a.

The HPSI and LPSI Motor Operator Valves (MOV) are closed.

b.

The MOV's are tagged shut and the operators have been given

instructions regarding not opening the MOV's.

c.

The plant procedures which require MOV cycling have been held

in abeyance until check valve testing has been satisfactorily

accomplished.

The Resident Inspector has verified that the above actions have

been performed and that closure of the HPSI and LPSI check valves

does not constitute an unreviewed safety question.

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.

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3.

Monthly Maintenance Observation

4.

Station maintenance activities of safety related systems and com-

ponents listed below were observed/reviewed to ascertain that they

were conducted in accordance with approved procedures, regulatory

guides and industry codes or standards and in conformance with

technical specifications.

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 qualified personnel; parts and materials used were properly certi-

fied; radiological controls were implemented; and, fire prevention

controls were implemented.

The following activities were examined:

a.

81-EPS-042 and -043: preventive maintenance activities on

emergency diesel-generators

b.

81-EPS-039: overhaul of emergency diesel air-start motor

c.

81-ESS-067:

replacement of a "snubber" (hydraulic shock

suppressor) found with low fluid level

d.

81-ESS-076:

electronic adjustments to safety injection ac-

cumulator level instrumentation.

The written record on this

item is unclear both as to identification of the problem and

description of corrective action.

Personnel interviews were

successful in gaining accurate information, but this may not

have been possible were the activity not a recent one.

This

was discussed at the Management Interview.

e.

81-RPS-006:

repeat of surveillance test MI-2 to verify absence

of instrument "drift" observed in testing of RPS trip units.

No items of noncompliance or deviations were identified.

Monthly Surveillance Observation

The inspector observed technical specifications required surveillance

testing on the systems/components identified below, and verified that

testing was performed in accordance with adequate procedures, that

test instrumentation 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 the individual directing the test, and that

any deficiencies identified during the testing were properly reviewed

and resolved by appropriate management personnel.

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The inspector

a.

S0-04

b.

MC-11

c.

R0-13

d.

FT-2

e.

M0-29

witnessed portions of the following test activities:

Pressure Test of Containment Entrance/Exit Hatch

Safeguard Boron Samples (SI Bottles Only)

Test of the Normal Shutdown Sequencers.

Problems

occurred in conduct of R0-13 with both shutdown

sequencers.

The inspector followed licensee immediate

actions and will review corrective actions for a re-

sulting Event Report during a future inspection.

Containment Building Post-Tensioning System

Engineered Safety System Alignment

Completed data for several tests performed in May 1981 were reviewed.

Review of M0-23 "Inservice Test Procedure (Low Pressure Safety In-

jection Pumps)" revealed the following discrepancies:

a.

Temporary Change 81-291 requires attachment of a recent cali-

bration sheet for internal calibration of PT-504 Data Logger.

This sheet was not attached.

b.

Paragraph 5.3.3 and 5.4.3 require the serial number and cali-

bration due date of a pressure test gauge be recorded.

This

was not performed.

c.

Paragraph 5.4.3 requires recording the time the low pressure

safety injection pump was stopped.

This was not performed.

d.

Paragraph 7.4 requires attachment of a calibration sheet for

the pressure test gauge.

This was not performed.

e.

Paragraph 5.3.5 requires a second person verify that valve

MV;...3202, "Discharge to the "B" Low Pressure Injection Pump"

is

locked and so signify by signature.

This was not performed.

Prior to review by this inspector, M0-23 had gone through four

levels of review and the items listed above had not been identified

by t~e licensee17s dis~repancies.

~s shown above and stated in a ..

previous report-

the inspector believes the plant lacks an effective

procedure.review process.

This concern was !fiscussed with plant

management on June 5, 1981, and at the Management interview.

Imple-

mentation of procedures for surveillance and testing of safety-related

equipment is a requirement of Technical Specification 6.8.1.c. The

examples above of failure to implement several requirements of

procedure M0-23 thus constitute an item of noncompliance against the

referenced Specification.

No other noncompliance and no deviations were identified.

lf

IE Inspection Report No. 50-255/81-06

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-*

5 .

Licensee Event Reports Followup

Through direct observations, discussions with licensee personnel,

and review of records, the following event reports were reviewed to

determine that reportability requirements were fulfilled, immediate

corrective action was accomplished, and corrective action to prevent

recurrence had been accomplished in accordance with technical speci-

fications.

a.

(Closed) LER 81-13 and LER 81-15 "Low Safety Injection Tank

Boron Concentration." During sampling of the safety injection

tanks (SIT) on March 17, 1981 and April 14, 1981, the boron

concentration of SIT-82B was found below the requirements of

Technical Specification 3.3.1.

Boron concentration was restored

to the T.S. limit within the time allowed.

Dilution of the

boron concentration is believed caused by slow inleakage of

primary coolant system water.

Repairs to the valves in the

leakage path will be made during the refueling outage.

Interim

corrective action is to increase the sampling frequency to

twice monthly and any time the SIT water is lowered, as level

is also being affected by the inleakage.

Graphs have been

prepared for the operators to correlate concentration and

level, as an aid to making any necessary adjustments within the

time limits of the license.

Primary system inventory loss by

this leakage is included in the determination of "unidentified"

leakage, which has remained well within specification limits.

b.

(Closed) LER-81-012 "Safety Injection Tank Low Level." During

sampling of SIT 82B on March 31, 1981, the low level alarm for

SIT 82A

alarmed, resulting in two SIT(s) with low level.

c.

Level was restored to the tanks within the time limits of the

Technical Specification.

Leakage through the control valve for

SIT-82A caused the inadvertent level decrease.

Repairs to the

control valve will be made during the next refueling outage.

(Closed) LER-81-01 "Inoperable Station

Inspection Report No. 50-255/80-24 for

item and the associated noncompliance.

dated March 10, 1981 for the corrective

Batteries." See IE

a description of this

See Confirmatory Order

action.

No items of noncompliance or deviations were identified.

6.

IE Circular Followup

For the IE Circulars listed below, the inspector verified that the

Circular was received by the licensee management, that a review for

applicability was performed, and that if the circular were applicable

to the facility, appropriate corrective actions were taken or were

scheduled to be taken .

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7.

a.

(Closed) IE Circular 79-05, "Moisture Leakage In Stranded Wire

Conductors."

b.

(Closed) IE Circular 80-17, "Fuel Pin Damage to Water Jet From

Baffle Plate Corner."

t.

(Closed) IE Circular 80-18, "Safety Evaluation for Changes to

Radioactive Waste Treatment Systems."

d.

(NJ A) IE Circular 80-20, "Changes in Safe-Slab Tank Dimensions."

e.

(Closed) IE Circular 81-02, "Performance of NRG-Licensed In-

dividuals While on Duty."

f.

(Closed) IE Circular 81-03, "Inoperable Seismic Monitoring

Instrumentation."

g.

(Closed) IE Circular 81-05, "Self-Aligning Rod End Bushings for

Pipe Supports."

No items of noncompliance or deviations were identified.

Followup on Previously Identified Items

(Closed)

Noncompliance item 2, IE Inspection Report No. 50-255/81-06:

Improper storage of flammable liquid.

The licensee 1 s actions as

stated in his letter dated June 15, 1981, were verified and considered

appropriate.

No items of noncompliance or deviations were identified.

8.

Spent Fuel Pool Modifications

This inspection included final review of quality documentation

relating to removal of the original spent fuel storage racks and

replacement with new, high density racks to increase2

7~71 pool

storage capacity.

Previous reviews and observations- -

had covered

much of this activity.

While minor corrective action or unresolved

items remain open, none affect current acceptability and use of

the new racks.

No items of noncompliance or deviations were identified.

9.

Review of Plant Activities

2/

}_J

During the months of January thru June, 1981 the inspector

reviewed the following activities:

IE Inspection Report No. 50-255/79-05

IE Inspection Report No. 50-255/81-06

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a.

Review and Audits

On April 22 and June 4, 1981, the inspector sat in on offsite

and onsite safety review committee meetings.

The inspector

verified that provisions of technical specifications dealing

with membership, review process, frequency, and qualifications

were met.

The inspector also verified that decisions made were

reflected in the meeting minutes and that corrective actions

proposed were taken.

b.

Training

The inspector attended one of the licensee's operator quali-

fication lecture series and verified that lesson plan objectives

were met and that training was in accordance with the approved

operator qualification program schedule and objectives.

c.

Environmental Protection

On April 9, 1981, the inspector verified the installation and

operability of five sampling/monitoring stations and associated

equipment and reviewed records for completeness and accuracy.

d.

Security

On March 10, 1981, the inspector observed weapons training and

qualification for newly-hired security officers.

e.

Licensee Action Concerning Identified Problems

The inspector reviewed corrective actions taken by the licensee

pertaining to recurring failures and resolution of identified

discrepencies involving safety-related components.

Approximately

thirty Deviation Reports covering about a two month period in

late 1980 were examined.

No trends or recurring failures were

identified.

Licensee followup on discrepancies related to

safety equipment was considered proper.

The inspector noted both the frequency of documented corrective

actions required and the fraction of items caused by personnel

errors and procedure violations seem to be decreasing.

No items of noncompliance or deviations were identified.

10.

Management Interview

A management interview (attended as indicated in Paragraph 1) was

conducted following completion of the inspection on July 3, 1981.

The following items were discussed, with licensee response as in-

dicated.

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. J.

a.

The inspectors described the scope and areas of inspection.

b.

Inspector verification of actions on the April 20, 1981 Generic

Order was discussed. (Paragraph 2)

c.

A potential problem with accurate documentation of maintenance

activities was noted (Paragraph 3.d).

The licensee pointed out

an accurate determination and description of needed repairs

cannot always be made prior ,to commencement of work, when the

documentation is initially prepared.

d.

The apparent noncompliance was specifically identified and

discussed (Paragraph 4), the emphasis being on a proper review

by the licensee to assure important activities are correctly

done.

The licensee agreed the review process had not been

functioning as needed and indicated improvements had been under

consideration and were, in fact, being implemented beginning

early in June, 1981.

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