ML18052A403
| ML18052A403 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/11/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8605010026 | |
| Download: ML18052A403 (6) | |
Text
consumers Power POWERINli MICHlliAN'S PROliRESS*
General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 April 11, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
SUPPLEMENTAL RESPONSE TO IE INSPECTION REPORT 85-027 Kenneth W Berry Director Nuclear Licensing NRC letter dated March 12, 1986 transmitted the results of their review of our response to IE Inspection Report 85-027.
Our original response for IE Inspection Report 85-027 dated January 22, 1986 was judged to be in need of supplemental information.
The following is that requested supplemental information.
Item 1:
Violation 255/85027-01 As required by 10CFR50.49 and as stated in Consumers Power Company's letter dated November 30, 1984, eight thermostats related to the Safeguards Equipment Room air coolers were to have qualified replacements installed by March 31, 1985.
Contrary to the above, the licensee determined on September 9, 1985, that the planned modification work to install qualified replacement thermostats had not been completed.
Response
Corrective Action Taken And Results Achieved The root cause of the occurrence was determined to be personnel error in the administration of the project which was controlling the installation of the environmentally qualified thermostats.
This function was the responsibility of our off-site based engineering projects group.
The engineering projects group believed that full responsibility for installation of the thermostats had been transferred to the plant's engineering group.
However, since the OC0486-0071-NL04 8605010026 860411 PDR ADOCK 05000255 G
PDR APR 14 1986 E_; o/ \\\\\\,
J G Keppler, Administrator Big Rock Point Plant Supplemental Response to IEIR 85-027 April 11, 1986 engineering projects group failed to utilize the appropriate formal mechanism to revise the scope of their responsibility, neither the engineering projects group nor the plant engineering group assumed responsibility for the subject thermostats.
Utilization of the formal scope change mechanism for the transfer of project responsibility has been strongly communicated to the engineering projects group.
Environmentally qualified thermostats (temperature switches) were installed in September, 1985.
2 While not contributing to the cause of the error, a potential opportunity to detect the omission was lost when the November 30, 1984 commitment to install qualified thermostats by March 31, 1985 was not identified for input into the commitment tracking system.
This occurrence and the importance of identifying all commitments were discussed with the personnel responsible for entering and tracking commitments.
Corrective Actions To Be Taken To Avoid Further Violation The above corrective actions have been completed and sufficiently address the root cause of the violation.
No further actions are necessary.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Item 2:
Violation 255/85027-02 10CFR50, Appendix B, Criterion XVI states in part:
"Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." Nuclear Operations Department QA Standard Q0-1 "Corrective Action and Control of Nonconforming Items" requires that an Event Report be initiated for potential violations of the Technical Specifications (Section 5.3.1), that the Event Report be reviewed by the Corrective Action Review Board (CARB) within one working day (Section 5.2.4), and a determination made if immediate corrective action is required.
Technical Specification 4.17.2 requires monthly verification of valve position and annual stroking of each testable valve in the flowpath for the fire suppression water system.
Administrative Procedure 9.23 "Technical Specification Surveillance Procedure Implementation and Corrective Action" requires that action be taken to complete a missed test as soon as possible (Section 6.7).
Contrary to the above, an audit of fire protection conducted September 30 through October 4, 1985, resulted in a finding that a fire suppression water system valve was not being checked as required by Technical Specification 4.17.2.
Action was not taken to test the valve until the evening of November 1, 1985.
OC0486-0071-NL04
J G Keppler, Administrator Big Rock Point Plant Supplemental Response to IEIR 85-027 Ap~il 11, 1986
Response
Corrective Actions Taken And Results Achieved The occurrence was caused by the failure of responsible plant individuals to recognize the potential implications of the audit finding and initiate appropriate corrective actions per Palisades Administrative Procedure 3.03, "Corrective Action", when briefed regarding the finding.
Contributing to the occurrence, was a lack of sensitivity to the immediacy of the problem on behalf of the audit personnel.
The responsibilities of timely identification of problems and initiation of corrective actions were reiterated in a memo distributed to all appropriate plant personnel.
Additionally, the incident was reviewed with all audit section personnel.
Quality Assurance Department procedures have been revised to specifically address the auditor's responsibility to notify appropriate plant personnel regarding violations and potential violations of license requirements which are discovered during audit and surveillance activities.
Corrective Actions To Be Taken To Avoid Further Violation No further actions are necessary.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Item 3 (a):
Your response does not address the repeated inoperability of the SITs and the lack of controls to anticipate inoperability.
Please discuss your plans for compensatory measures during future periods of inoperability (re: Item 1, below).
- 1.
"With known leakage into the SITs and a history of prior problems, no action was taken to anticipate the amount of dilution which could be tolerated before the concentration of boron fell below the TS Limit (the PCS boron concentration was at 94 ppm)."
Response
3 As stated in our initial response, Primary Coolant System (PCS) in-leakage into the SITs and the resulting SIT level and dilution problems recurred at an accelerated frequency in November 1985, after a relatively stable operating period.
Administrative controls such as leakage trending, increasing SIT boron sampling frequency and maximizing the as-left boron concentration of the SITs had been utilized in the previous operating cycle and were again a matter of practice in November 1985 to address the in-leakage problem.
Unfortunately, these practices were not sufficient to fully preclude occasional entry into the corresponding Technical Specification Limiting Conditions for Operation (LCO).
OC0486-0071-NL04
J G Keppler, Administrator Big Rock Point Plant Supplemental Response to IEIR 85-027 April 11, 1986 4
The primary source of our past SIT in-leakage problem was through the SIT fill-and-drain lines, which occurred due to pressurization of the fill-and-drain header from leakage past one or more PCS loop check valves.
In addition to repairing many of the system valves, including two suspect loop check valves, we have currently revised our method of operating this system by maintaining CV-3069 in the open position to preclude pressurization of the fill-and-drain header.
The overall result is a greatly reduced opportunity for in-leakage into the SITs.
We will be able to anticipate the potential onset of SIT in-leakage problems by monitoring the system pressure between the loop check valves and the SIT pressure control valves.
An increase in pressure would be indicative of leakage past a PCS loop check valve.
Subsequent action would then depend upon the individual circumstances and the extent of the leakage problem.
- However, we have not, and do not intend to routinely allow the Technical Specification limit to be reached before appropriate compensatory measures are initiated.
Item 3 (b):
We do not understand how you plan to anticipate level and dilution problems in the SITs when the indicator system becomes inoperable during times that leakage exists. Additionally, please provide more detailed information regarding the planned modification to the level indicating system (re: Item 2, below).
- 2.
"The level indicator and administrative alarms for the SIT were not functional and did not warn the operator he was approaching a TS limit.
Inoperability of these indicators and alarms have been contributors to prior events of SIT inoperability.
Response
Level indication for each SIT is accomplished by two distinct systems.
One system incorporates a float-type level switch which alarms at the high and low level Technical Specification limits.
This system has proven to be extremely reliable.
The second system provides continuous level indication as sensed by a d/p transmitter, which utilizes the SIT outlet pipe as one reference leg.
This system has proven reliable except during periods of in-leakage from the PCS through two check valves (loop check valves and SIT check valves) in series.
The resulting temperature change and corresponding water density change within this reference leg which occurs with multiple check valve failures introduces significant error into the level indication.
Consequently, warning of the approach to the Technical Specification limit is severely impaired in this instance.
We are considering several proposed system modifications which would relocate the lower instrument tap to an alternate location, and thereby exclude the SIT outlet pipe as an instrument reference leg.
However, the proposed modification appears to be very costly due to the considerable re-piping necessary inside the Containment Building.
Since we feel we have solved the root cause problem of leakage through multiple check valves, a final decision OC0486-0071-NL04
J G Keppler, Administrator Big Rock Point Plant Supplemental Response to IEIR 85-027 April 11, 1986 5
to leave the system as currently designed may be reached.
Should we determine that the level indication system will not be modified as previously committed, we will advise you regarding our decision.
Item 3 (c):
The paragraph does not address the root cause for the operator error. It is also unclear why the administrative controls such as status boards, operating logs, and turnover sheets were not effective in preventing the oversight (re: Item 4, below).
- 4.
"The operators did not recognize that they already had an Emergency Core Cooling Component inoperable and conducted feed and bleed by filling above the high level limit and draining below the low level limit which was in violation of the Technical Specifications."
Response
At Palisades, the primary responsibility for assessing plant status with respect to the Technical Specifications rests with the two Senior Reactor Operators (SROs; Shift Engineer and Shift Supervisor) who are staffing the shift.
In this instance, appropriate administrative controls were in place to apprise the Shift Engineer and Shift Supervisor of the plant status.
Together, the SROs on shift erred in relating the existing plant condition to the appropriate Technical Specification.
The error was subsequently detected by a third SRO who was available at the time, but was not a member of the shift complement.
The incident is considered an isolated occurrence.
The importance of thoroughly evaluating the effect of equipment inoperability upon Technical Specification requirements has been emphasized to all SROs.
Item 4:
Safety Injection Tank (SIT) In-leakage Update It is requested that you review and update as appropriate your original response based on experience gained during the recent refueling outage with respect to this system.
Response
Since the latest check valve repairs were completed in March 1986, the system has been operated for over two weeks with no evidence of unacceptable leakage past the PCS loop check valves, and consequently no problems with SIT in-leakage.
This is positive indication that the valve maintenance and our revised method of operating this system with the fill-and-drain header depressurized were effective in correcting past problems.
We will continue to closely monitor the system for evidence of a deteriorating condition.
OC0486-0071-NL04
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J G Keppler, Administrator Big Rock Point Plant Supplemental Response to IEIR 85-027 April 11, 1986 6
During the past two week period, we have identified minor out-leakage from one of the SITs.
Without SIT in-leakage, however, the level indication system has functioned properly to warn the operators of the condition, resulting in the initiation of appropriate actions prior to reaching the Technical Specification limit.
Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Palisades OC0486-0071-NL04