ML18046B136
| ML18046B136 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/23/1981 |
| From: | Boyd D, James Heller, Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18046B134 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.3, TASK-1.C.6, TASK-2.B.4, TASK-2.D.3, TASK-2.E.1.2, TASK-2.E.3.1, TASK-2.E.4.2, TASK-2.F.2, TASK-2.G.1, TASK-3.D.1.1, TASK-3.D.3.3, TASK-TM 50-255-81-23, NUDOCS 8112160227 | |
| Download: ML18046B136 (9) | |
See also: IR 05000255/1981023
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/81-23
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site,
Covert, MI
License No. DPR-20
Inspection Conducted:
October 4-7, 12-16, 19-21, and 26-30, 1981
d*-4/d
Inspectors:
B. L. Jor~;;;;~*
r~~
~-K-~d
Approved By:
D. C. Boyd, Cliief,
Reactor Projects Section lA
Inspection Summary
//-23-- 8 I
//- 2 3-- 81
//- 23-~fl
Inspection during October 4-30, 1981 (Report No. 50-255/81-23)
Areas Inspected:
Routine resident inspection program activities including:
operations during long-term shutdown; refueling activities; maintenance and
modifications; procedures; and followup of actions on NUREG-0737 items.
The
inspection involved a total of 160 inspector-hours onsite by two NRC inspec-
tors, including 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> onsite during off-shifts.
Results:
Of the five areas examined, no items of noncompliance or deviations
were identified in three areas.
Three items of noncompliance (Severity Level
V - welding without fire extinguisher - Paragraph 2; Severity Level VI -
liquid radwaste collection without procedure - Paragraph 2; Severity Level V -
refueling procedure noncompliance - Paragraph 3) were identified in the
remaining two areas .
1.
DETAILS
Persons Contacted
- R. W. Montross, General Manager
~rJ. S. Rang, Operations/Maintenance Superintendent
- H. J. Palmer, Technical Superintendent
- G. H. R. Petitjean, Technical Engineer
- R. E. McCaleb, Quality Assurance Administrator
D. K. Powers, Shift Technical Advisor
W. S. Skibitsky, Operations Superintendent
J. A. Meineke, Technical Engineer
W. L. Burmeister, Shift Technical Advisor
W. E. Drummond, Reactor Operator
R. S. Cater, Reactor Operator
S. Ghidotti, Shift Supervisor (SRO)
A. S. Kanicki, Shift Supervisor (SRO)
D. W. Kaupa, Shift Supervisor (SRO)
G. L. Pothoff, Reactor Operator
E. I. Thompson, Shift Supervisor (SRO)
S. F. Pierce, Radioactive Materials Control Supervisor
- B. L. Schaner, Operation Supervisor
K. M. Farr, Public Affairs Director
W. E. Adams, Senior Engineer (STA)
D. P. Spry, Property Protection Advisor
J. L. McVay, Administrative Supervisor
W. M. Hodge, Plant Property Protection Supervisor
R. J. Stanton, Reactor Operator
D. M. Kennedy, General Engineer
- Denotes those present at Management Interview on November 3, 1981.
Numerous other members of the plant Operations/Maintenance, Technical,
and Chemistry/Health Physics staff were also contacted briefly.
2.
Activities During Long Term Shutdown
The inspector observed selected licensee activities being performed
during the current shutdown condition to ascertain compliance to ap-
plicable requirements.
a.
Control Room
The inspector observed control room operations, reviewed applic-
able logs and conducted discussions with control room operators
during the month of October 1981.
The inspector verified adherence
to limiting conditions for operation at cold shutdown, proper
shift manning, adherence to selected procedures, and instrument/
recorder operations.
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b .
Facility Tours
Tours of the containment, turbine and auxiliary buildings, and
plant grounds were conducted to:
assess general plant/equipment
conditions (including standby equipment); verify that maintenance
requests have been initiated for equipment in need of maintenance;
examine plant areas (including cabinet interiors) for fire hazards;
and verify that ignition sources and flammable material being con-
trolled in accordance with licensee procedures.
During a containment tour on October 5, 1981, the inspector
observed a contractor preparing to weld piping in a fabrica-
tion area on the 649 foot level.
The inspector asked the crew
if they had a fire extinguisher readily available? The crew
responded they would obtain a fire extinguisher prior to welding.
The inspector returned to the area approximately 30 minutes later
and observed the crew welding without a fire extinguisher present.
At this point the inspector informed the crew that welding without
a fire extinguisher readily available was a violation of the Fire
Protection Implementing Procedures, and the crew stated they would
obtain a fire extinguisher prior to continuing.
The inspector then
notified the Plant Property Protection Supervisor.
The inspector returned to the area within 30 minutes with the
Property Protection Advisor, who noted a fire extinguisher was
now present but the crew had vacated the area without stationing
a fire watch to maintain surveillance for at least 30 minutes
after the welding operation was completed.
Failure to have a
fire extinguisher readily available and failure to maintain a
fire watch for at least 30 minutes after completion of welding
is in violation of Palisades Fire Protection Implementing Pro-
cedure, Section 7, Paragraph 5.5.3.
Adherence to this procedure
is a requirement of Technical Specification 6.8.1.a.
The above
example constitues an item of noncompliance with the reference
Technical Specification.
Prior to completion of this inspection
period, the licensee took the following corrective actions:
(1)
Hot work operations were stopped on that shift until the crews
were rebriefed on the Fire Protection Implementing procedures.
(2)
Members of each subsequent shift were rebriefed prior to
commencing work on their shift.
(3)
The Property Protection Advisor will continue Fire Protec-
tion Implementing procedures briefing during General Employee
Training.
The inspector has no further questions in this area.
The inspector observed plant housekeeping/cleanliness conditions
and verified implemention of radiation protection controls.
The
inspector by observation and direct interview verified that the
physical security plan was being implemented in accordance with
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c.
the station security plan.
The inspector independently surveyed
one radwaste truck awaiting shipment.
The inspector observed
fire fighting training on October 15, 1981, for plant fire brigade
members.
Review of Corrective Action
During a review of logs and event reports issued for 1981, the
inspector noticed that the containment sump was drained by a
method not recognized in SOP - 17B, Paragraph 6.10, the approved
procedure for this function.
The method used involved connecting
a hose to the test tap between the automatic containment isolation
valves and opening the tap valve and the inboard isolation valve
to drain the sump.
Event Report E-PAL-81-094 documented the
licensee's concern that this lineup may have violated the intent
of refueling Technical Specification 3.8.b, which requires that
all automatic containment isolation valves be operable or at least
one valve in each line be closed during fuel moves.
Fuel was
being moved while this temporary lineup existed.
The inspector
identified an additional concern, in that failure to have an
approved procedure to drain the sump in the above manner, is a
violation of Technical Specification 6.8.1.a which, by reference
to Regulatory Guide 1.33 requires approved procedures for collec-
tion of liquid radioactive wastes.
Two items of noncompliance and no deviations were identified in
this area.
3.
Refueling Activities
The inspector examined the periodic testing of refueling related
equipment; observed four shifts of the fuel handling operations
(removal and insertion) and verified the activities were performed
in accordance with the Technical Specifications and approved pro-
cedures; verified that good housekeeping was maintained on the
refueling area; and, verified that staffing during refueling was in
accordance with Technical Specifications and approved procedures.
During source transfer on October 5, 1981, the inspector observed a
violation of SOP-28, paragraph 3.1 which requires the spent fuel pool
elevator, two-speed gear box shall be mechanically restricted to pre-
vent any gear changes when a fuel bundle is in the elevator.
Source
transfer requires use of the .spent fuel pool elevator to raise or lower
the fuel bundle while transferring the source.
The inspector observed
an operator place an irradiated fuel bundle in the elevator~ raise the
elevator in slow speed and lower the elevator in fast speed.
The in-
dividual was asked if he had shifted gears,which he answered in the
affirmative.
The inspector searched the area and could not find
evidence that the gear box had been mechanically restricted.
The
inspector then notified the Shift Supervisor, Technical Engineer and
the Operations Superintendent.
Failure to have the gearbox mechanically
restricted and shifting gears with a fuel bundle in the elevator is in
violation of SOP-28, Parapgraph 3.1.
Adherence to this procedure is a
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requirement of Technical Specification 6.8.1.b.
The above example
constitutes an item of noncompliance with the referenced Technical Spec-
ification. Prior to completion of the inspection period the licensee
undertook the following corrective actions:
a.
Instructed operators during subsequent source handling operations
of restrictions in SOP-28.
b.
Mechanically restricted the two-speed gear box.
c.
Added a requirement to the fuel elevator check sheet to require
a caution tag to be installed on the mechnical gear restrictor.
d.
Instructed the operator involved.
e.
Routed memo to all Operations Department personnel explaining the
reason why the gear box cannot be shifted when a bundle is in the
elevator.
The inspector has no further questions in this area.
Several completed procedures/checklists associated with fuel movement
were reviewed.
The results of this review are listed below:
a.
CL 28.1 Refueling Communication Checklist:
An operator had initialed, on 9 of 35 checklists reviewed, that
headphones conference was in use, whereas the other operators N/A
this signoff on 26/35 checklist reviewed.
This item was discussed
with the operation supervisor.
b.
CL 28.4 Refueling Machine Checklist:
The checklist does not contain a signoff for "supervisor review"
or for "completed by" and does not signify how many pages the
checklist contains.
This item was discussed with the operation
supervisor and appropriate changes made to the procedure.
c.
GCL 11.2 Refueling Operation Checklist:
(1)
Step 11 requires a shiftwise signoff verifying proper con-
figuration of the equipment hatch and personnel hatch.
This
was not performed as required during all shifts of fuel
transfer.
(2)
Step 12 requires greasing of the tilt machine hydraulic pump
crank bearing every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operations.
This was only
signed once during the approximately 11 days of fuel shuffling.
(3)
Step 13 requires the elevator checklist FHS0-1 be completed
each shift the elevator was used.
This was not signed at any
time during use of the elevator.
The inspector did search the
spent fuel pool area and found a copy of FSH0-1.
Review of
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FSH0-1 shows that the checklist was not completed each shift
the elevator was used .
(4)
Step 11 addresses proper verification of the personnel hatch
and equipment hatch but does not require verification of the
escape hatch.
(5)
All items were discussed with the operation supervisor and
operation superindent.
GOP-11, Step 3.2 requires completion of CL 11.2 during each shift
of fuel transfer.
Adherence to GOP-11 is a requirement of Technical
Specification 6.8.1.b., Items 1, 2, and 3 above are examples of non-
compliance to the referenced Technical Specification.
d.
Checklists 28.2, 28.3, 28.5, 11.1, 3.3 and 27.2 were reviewed and
no items identified.
The two problems identified; failure to mechanically restrict the fuel
pool elevator and failure to complete GCL 11.2 are treated as one non-
compliance with two examples.
No deviations were identified.
4.
Maintenance and Modifications
The inspectors observed work activities involving maintenance or modi-
fications of plant systems or components.
These observations were
conducted to verify proper exercise of administrative controls over
these activities including:
approvals for removal from and return to
service; provision of appropriate QC hold points; provisions for testing
following work; control of parts and materials used; management of any
identified deficiencies, and; general housekeeping and cleanliness con-
trols.
The inspector selectively verified activities were accomplished
by qualified personnel using approved procedures.
a.
Station battery replacement:
the licensee identified battery rack
welding deficiencies traceable to the manufacturer and initiated
corrective action which may include a report under 10 CFR 21.
b.
Shutdown cooling system:
replacement of damaged check valves;
installation of check valve integrity testing connections.
c.
Auxiliary feedwater system:
welding activities.
d.
Reactor vessel gaseous vent:
fabrication and installation activities.
e.
Safety injection accumulators:
wiring connections; installation
and restraint of motor control centers outside containment for
accumulator outlet valve motor-breakers.
f.
Control rod drive connector repair.
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The inspector received notification from a contractor employee on
October 5, 1981, that a knife blade in use at an electrical jobsite had
broken and been lost inside a safety-related electrical conduit.
The
employee was concerned no action would be taken to report this matter to
the licensee for corrective action.
The matter was discussed with a
licensee representative, who determined the contractor had documented
the occurrence for reporting to the licensee.
Corrective action was
initiated to assure the subject conduit would not be further utilized
in a manner (such as cable pulling) which could result in damage from
the lost blade.
No items of noncompliance or deviations were identified.
5.
Procedures
Selected licensee procedures were examined during this inspection to
determine technical adequacy; consistency to license requirements; and
proper development, review, approval, and revision.
Variously located
controlled copies of the procedures were verified to have the latest
revisions posted.
a.
Systems Operating Procedures (SOP's)
(1)
SOP-3 Safety Injection and Shutdown Cooling System
(2)
SOP-5 Containment Air Cooling and Hydrogen Recombining System
(3)
SOP-8 Main Turbine and Generator Systems
(4)
SOP-21 Fire Protection System
b.
Emergency Operating Procedures (EOP's)
(1)
EOP-6 Main Steam Line Break/Main Feedwater
(2)
EOP-10 Control Room Evacuation
c.
Off Normal Procedures (ONP's)
(1)
ONP-3 Loss of Feedwater
(2)
ONP-4 Containment Isolation
d.
Administrative Procedure 9.0:
Plant Modifications
e.
Procedure CFH0-6:
Replacement of Damaged Control Rod
The reviews of the EOP's was accomplished utilizing NUREG/CR-2005,
"Checklist for Evaluating Emergency Procedures Used in Nuclear Power
Plants." .Some minor inconsistencies between the EOP's and the
NUREG/CR-2005 were noted in the review which were identified to the
licensee for his information.
No items of noncompliance or deviations were identified.
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6.
NUREG-0737 Followup
The inspection included a review of selected licensee actions to im-
plement requirements of NUREG-0737, "Clarification of TMI Action Plan
Requirements."
a.
(Closed) Item I. C. 5, "Feedback of Operating Experience."
Licensee actions as described in his letter of December 19, 1980,
and September 28, 1981, were verified and deemed appropriate.
b.
(Closed) Item II.B.4, "Training for Mitigating Core Damage."
Implementation and completion of the licensee's training program
for this subject, as described in his letters dated December 19,
1980, and September 28, 1981, was examined.
Some Shift Technical
Advisors (STA's) completed training after October 1, 1981, but before
performing on actual STA duties.
As noted in the licensee's letter
of December 19, 1980, all topics of Enclosure 3 to the March 28,
1980, NRC letter (H. R. Denton to All Power Reactor Licensees) on
this subject were not covered in detail.
The inspection, however,
noted only very minor variances, and concluded proper training was
provided.
c.
(Closed) Approved Technical Specification Changes covering the
following were received with Ammendment 67 dated October 8, 1981:
(1)
Item I.A.1.1.2 Shift Technical Advisor
(2)
Item I.A.1.3.2.B Shift Manning
(3)
Item II.D.3.2 Valve Position Indication
(4)
Item II.E.1.2.2.B Auxiliary Feedwater System Initiation and
Flow
'
(5)
Item II.E.3.1.2 Emergency Power for Pressurizer Heaters
(6)
Item II.F.2.2 Instrumentation for Detection of Inadequate Core
Cooling
(7)
Item II.G.1.2 Power Supplies for Pressurizer Relief Valves,
Black Valves, and Level Indicators
(8)
Item III.D.1.1.2 Primary Coolant Outside Containment
(9)
Item III.D.3.3 Inplant Radiation Monitoring
Ammendment 67 included an accompanying Safety Evaluation which
addressed Item II.E.4.2, "Containment Isolation Dependability;"
concluding changes to the existing Technical Specifications were
not required for this item.
No items of noncompliance or deviations were identified.
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'
7.
Contractor Employee Complaints
The inspectors received complaints from two contractor employees during
the inspection period.
One individual expressed concerns relating both
to occupational safety questions and to licensee adherence to radiation
protection procedure requirements.
Some review of these matters was
performed and discussions were held with licensee representatives (Safety
Committee Chairman and health physicist) to apprise them of the concerns.
The other individual expressed a separate and different concern relating
to radiation protection practice.
This matter and those of the first
individual relating to radiation protection were discussed with and
referred to specialists in the NRC Region III Office of Inspection and
Enforcement for final review during a future inspection.
8.
Management Interview
A management interview, attended as indicated in Paragraph 1, was con-
ducted following completion of the inspection, on November 3, 1981.
The
following matters were discussed:
a.
The inspectors summarized the scope and content of the inspection
as described in these Details.
b.
The apparent items of noncompliance were specifically discussed
by the inspectors, including the determination that appropriate
corrective and preventive actions had been completed for the item
involving welding without a fire extinquisher available.
c.
The licensee indicated corrective and preventive actions were con-
sidered complete for the item involving fuel inspection elevator
gear changing, and requested inspector review of the matter.
The
inspectors subsequent review determined proper licensee actions had
been completed.
d.
Preliminary review and referral of complaints covering radiation
protection and occupational safety concerns, submitted to the in-
spectors by workmen, were discussed .
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