ML18052B436
| ML18052B436 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/23/1987 |
| From: | Cox T, Falevits Z, Jablonski F, Kropp W, Stasek S, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052B434 | List: |
| References | |
| 50-255-87-27, NUDOCS 8801060184 | |
| Download: ML18052B436 (16) | |
See also: IR 05000255/1987027
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III*
Report No. 50-255/87027(DRS)
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Covert, Michigan
Inspection Conducted:
October 26-30 and December 17, 1987
1-/)~b~l~'
Inspectors:* T.~o~
Qy~
Approved By:
~~
z. F~1rvi~
c;.~
S. Stasek
7- .9 ~ C)_~~<:;~ 'fui-*
H. J£1tM
1
1~/,t::,7,
W. Kropp
Team Leader
7-~I Q.ga.et~o~'
Frank J. lJa~nski, Ch1ef
Maintenance and Outage Section
Inspection Summary
License No. DPR-20
t2/2 3/g7
Date '
12/23/zz
Date ~ *
- z/i
- i/81
Date
/2-0 3187
Dat'e
t
1z/2:r/1ri
Date
/2/23/87
Dat'i
/
Inspection on October 26-30 and December 17, 1987 (Report No. 50-255/87027(DRS))
Areas Inspected:
Special, announced team inspection of licensee action on
previous inspection findings; electrical and mechanical modifications;
electrical and mechanical maintenance activities; operations and systems using
selected portions of Modules 37702, 62700, 62702 and 92720.
Results:
In the areas inspected, two violations were identified (lack of timely
corrective actions, (Paragraphs 2.d and 3.d(3)) and failure to follow procedures
in electrical maintenance (Paragraph 3.c(l)). Overall the team concluded that
licensee performance was continuing to improve in the maintenance and
modification programs; thereby, contributing to the continued improvement in the
material condition of the plant.
~~01060184 87!229
ADOCK 05000255
Q
1.
Persons Contacted
Consumers Power Company (CPCo)
D. Hoffman, Plant Manager
DETAILS*
R. Brazezinski, Instrument and Control Superintendent
R. Fenech, Operations Superintendent
D. Joos, Planning and Administrative Manager
R. Kasper, Electrical Maintenance Superintendent
- C. Kozup, Technical Engineer
J. Lewis, Plant Technical Director
D. Malone, Nuclear Licensing Analyst
R. McCaleb, QA Director
R. Orosz, Engineering and Maintenance Manager
K. Osborne, Projects Superintendent
J. Palmisano, Systems Engineering Superintendent
R. Ricek, Operations Manager
H. Tauney, Mechanical Maintenance Superintendent
Nuclear Regulatory Commission (NRC)
B. Burgess, Section Chief, Projects Section 2A
F. Jablonski, Section Chief, Maintenance and Outage Section
T. Wambach, Licensing Project Manager
The above listed individuals attended the exit meeting on October 30,
1987.
Other licensee personnel were contacted as a matter of routine
during this inspection ..
- Attended exit meeting via telephone on December 17, 1987.
2.
Licensee Actions on Previous Inspection Findings
a.
(Closed) Open Item (255/86035-01):
Commitment for preventive
maintenance (PM) on the fluid drive on Coolant Charging Pump P-55A.
The inspector reviewed documentation to substantiate that PM
activities were identified for the fluid drives.
These PM activities
pertained to changing the fluid-drive oil every year and rebuilding
the fluid drives every five years.
This matter is closed.
b.
(Closed) Open Item (255/86035-04):
Commitment for PM on condenser
hotwell cleaning.
The inspector reviewed documentation to
substantiate that a PM for condenser hotwell cleaning was identified
and scheduled for implementation.
This PM was tp be performed during
refueling outages.
This matter is clos~d .
2
c.
(Closed) Open Item (255/86035-05):
Commitment for PM on feedwater
recirculation valve inspection.
The inspector verified that a PM
activity had been identified for implementation during refueling
outages.
This matter is closed.
d.
(Closed) Open Item (255/86035-137):
The worst limiting accident
analysis for the charging pumps is the Main Steam Line Break (MSLB)
which requires 68 gpm to the core.
This flow is equivalent to two
charging pumps.
Palisades has three charging pumps; however, only
the
11A
11 and
11C
11 charging pumps wil 1 start from a Safety Injection
Signal.
The Palisades Technical Specification requires that two
e.
pumps be operable, but does not distinguish between the three pumps.
At the time of this inspection, the licensee's status of this item
was closed.
Information provided to the inspector to substantiate
this position consisted of a proposed revision to the FSAR that did
not address this open item.
Upon further review, the inspector
determined that the licensee had erroneously identified this item as
closed based on a proposed revision to the FSAR for another NRC issue.
As a result, inconsistencies in the operability requirements for the
charging pumps existed in the operating procedures, FSAR, and
Technical Specifications for several months.
This is an example of
not taking adequate and timely corrective action, and is considered
a violation of 10 CFR 50, Appendix 8, Criterion XVI .(255/87027-0la).
Therefore, the open it~m is closed but has been upgraded to a
violation.
In addition, the inspectors determined that the licensee did not have
an adequate system to track or keep status of issues identified by
the NRC.
Specifically, the licensee did not have:
An established method to verify acceptability of actions planned
and/or implemented to close issues identified by the NRC.
Ongoing knowledge of the specific steps and/or documentation
required to close issues identified by the NRC.
i
These weaknesses should be reviewed by the licensee to ensure that
- timely closure of other NRC identified issues is accomplished.
This
is an open item (255/87027-02).
(Closed) Open Item (255/87023-01):
This item concerned the failure
of the mechanical maintenance organization to maintain the status of
replacement parts for maintenance work orders scheduled for work
during the outage.
Fourteen mechanical related work orders were on
hold for replacement parts and current procurement status was not
known.
During this inspection, the inspector noted that three of the
fourteen work orders were still on hold for parts. In addition to
these three, two more work orders had been added to the list due to
emergent work.
Mechanical maintenance personnel knew the current
status and were tracking the five procurements.
This matter is closed.
One violation was identified.
3
3.
Assessment of Maintenance and Modifications
This inspection was conducted to assess th~ licensee's progress regardin~
improvements in Palisades* maintenance and modification programs.
This
inspection was scheduled to coincide with a planned outage.
A previous
NRC inspection by Region III personnel assessed the licensee's planning
activities for this outage.
That inspection was conducted September 21-25,
1987, and documented in Inspection Report No. 50-255/87023.
Based on
results of this inspection, it appeared that the licensee's preoutage
planning activities were a success in further reducing the backlog of
maintenance work orders.
To assess the licensee's progress in improving the material condition of
the plant, the team evaluated specific areas of electrical/mechanical
maintenance and modification programs and system operations by review of
logbook entries, work orders, and modification packages, observation of
work and operations, and interviews.
Specific areas assessed included:
Threshold for placing equipment problems on maintenance work orders.
Corrective actions associated with equipment problems.
Progress towards the desired goal of approximately 50% of the
maintenance activities being classified as preventive maintenance.
Availability and accuracy of system design information.
Training of maintenance personnel.
Results of the inspection are documented in the following sections.
a.
Plant Personnel Perspectives
b.
The inspectors interviewed maintenance, operations, and QA personnel.
Those individuals interviewed were eight maintenance workers, two
maintenance.supervisors, three QA individuals, five control room
operators, and two shift supervisors.
The inspectors ascertained
that there was good morale, an attitude to perform activities right
the first time, continued improvement in communications between plant
departments, continued commitment by plant management to improve the
maintenance program, and continu~d commitment to improve the material
condition of the plant; however, management should continue to be
actively involved in plant activities to ensure continued improvement
in the material condition of the plant.
Design Control
The inspectors reviewed design change packages and modifications-*
performed by the licensee's on-site engineering organization to
determine technical adequacy and conformance to regulatory
4
requirements and industry standards.
Work associated with the* design
change packages and modifftations was examined .in the field. The work
examined was of acceptable quality and the work areas were clean and
organized.
During the review of the design change packages, the
inspectors focused specifically on 10 CFR 50.59 reviews, procedural
compliance, and the need for preventive maintenance.
( 1)
E'l ectrica l
- The inspectors selected the following electrical Facility Change
(FC) and Specification Change (SC} packages for review.
In
addition, the inspectors examined the field work associated with
these packages:
Addition of Local/Remote Transfer Switch to
Breaker, 152-106.
Addition of diodes to annunciator circuitry for
High Pressure Safety Injection (HPSI) motor .
operator valves (MOV) to eliminate signal feedback.
At the time of this inspection, the modification associated
with package FC-687 had been installed and tested while package
SC-87-14 was in the initial stages of design .
In regards to FC-687, the inspectors performed a detailed
document review and a visual inspection of the field installed
modification.
The facility change package contained documents
that pertained to: design reviews; 10 CFR 50.59 evaluations;
QA/QC requirements; testing requirements; and methods for
.installing the modifications. The licensee's review of this
package determined that the modification was adequately designed,
reviewed, and implemented; however, the inspectors determined
that Schematic Diagram E-5, Sheet 15, Revision 5 had not been
revised to incorporate modification FC-687.
The NRC previously
identified a violation in Inspection Report No. 50-255/86028
that identified electrical drawing as-built inaccuracies. The
- licensee's corrective action ta that violation included
establishment of a Configuration Control Project (CCP) to resolve
the electrical drawing inaccuracies. Effectiveness,of the CCP
could be adversely affected if management attention is not given
to future modifications. This matter is an unresolved item
(255/87027-03).
An associated concern not affected by FC-687, pertained to
Schematic Diagram E-129, Sheet 1, Revision C, which did not have
a switch development for local control switth 52/CS-L and did
not depict the field installed overcurrent relays test swffi:hes.
This concern should be resolved during the implementation of the
electrical walkdown portion of the CCP.
5
-
Another concern pertained* to resolutions of* an engineer's
comments on a document review sheet that were not included in ,
the resolution column; however, the resolutions did not have ari
adverse effect on FC-687.
The matter of assuring that
resolutions to comments are documented was discussed with the
licensee.
In regards to Specification Change SC-87-14, the inspectors
reviewed the preliminary design for technical adequacy.
was initiated as a result of a system functional evaluation test.
While performing this test, the licensee temporarily installed an
electrical jumper to simulate an electrical overload condition
on one motor operated valve (MOV).
Instead of activating an
alarm indicating one MOV overload, the control room operators
received alarms indicating two MOV overloads.
The licensee
determined that there was a feedback signal which caused the
erroneous alarms and diodes will be added in the annunciator
control circuitry to correct the problem.
The inspectors
reviewed the preliminary design associated with SC-87-14 that
appeared to resolve the feedback problem; however, it was unclear
to the inspectors why post modification testing, performed five
years ago for the original alarm i.nstallation, did not identify
the feedback problem. The licensee should determine why original
post modification tests did not identify the feedback problem and
apply any lessons learned to future modifications. This is an
open item (255/87027-04).
In conclusion, the inspectors determined that the licensee's
electrical design control process for modifications had
continuqd to improve and a positive attitude was noted during
discussions with field engineers. The inspectors determined
that the 10 CFR 50.59 evaluations were adequate .. Except for.
the concerns identified by the inspectors, procedural compliance
was acceptable.
.
(2) Mechanical
During this inspection*, the following mechanical FCs and SCs
were reviewed by the inspectors. Included was an inspection of
. field work associated with these design changes.
Fc,...773
Replacement of Atmospheric Steam Dump Valves.
Electro-Hydraulic Control (EHC) System
Modification
Replacement of Drain Valves for a Feedwater
Heater .
Snubber Reduction Programs.
Change MV-3232, Containment Spray Pump
Recirculation Valve, from Velan to a Vogt.
6
The documents in these packages were generally consistent with
the plant procedures used to control *and manage design*changes~
Some inconsistencies with current plant procedures were noted,
individually not serious, but collectively indicated that
additional attention to detail was required during the review
process.
The inspectors identified concerns with Safety
Evaluations (SE) (10 CFR 50.59); however, during a previous
inspection, Inspection Report 50-255/86035, concerns were
identified with the SE process and resulted in the issuance of
a violation (255/86035-152) that is still open.
At the time of
the inspection, the licensee had not revised Administrative
Procedure 3.07, "Safety Evaluation,
11 to resolve the violation.
Inspection Report 50-255/87018 also identified concerns with the
SE process.
During a meeting prior to the exit, the licensee
committed to revise Procedure 3.07 prior to January 1, 1988.
This commitment will be tracked with violation 255/86035-152.
The following concerns, not related to the SE process, were
identified:
(a) Preventive Maintenance (PM) requirements were not adequately
addressed for FC-725.
The Design Document Checklist
stipulated that maintenance requirements were applicable;
however, the PM procedures were not identified.
Also, there
was no objective evidence in the FC package that indicated a
review was conducted of the PM procedures for the
Atmospheric Dump Valves to determine applicability for the
new Masoneilan valves.
The existing PM procedures were
written for the originally installed Copes-Vulcan valves.
Pending further review, this is an open item (255/87027-05).
(b) The Design Input Checklist, Design Document Checklist, and
the Design Review Checklist in the package for FC-773 did
not specify any PM activity for the modified EHC components.
Although non-safety related, the EHC system's function is
important and lack of reliability could lead to spurious
plant trips.
Discussion with the Project Engineer
determined that PM was planned.
Pending further review of
the PM program for the EHC system, this is an open item
(255/87027-06).
(c) Section 15 of the Design Input Checklist for the EHC
modification did not identify any 11additional QA/QC
requirements;
11 however, an excerpt from Section 15 of the
checklist stipulated
11for certain jobs or special processes
not covered by the codes, additional QA/QC requirements may
be desired.
The case of a non-Q (non-safety-related) job
with high reliability aspects and a desire for QC is .. an *
example. 11
The inspectors expected QC involvement since the EHC system
requires high reliability to preclude unnecessary challenges
7
to the reactor systems, and previous Palisades experience
included reactor trips due to the EHC component problems ..
There was no evidence that personnel were involved in QC *
activities.
Future modifications of high reliability
systems with previous experience of causing reactor system
challenges will be evaluated for appropriate QC involvement
in a future NRC inspection.
This is an open item
(255/87027-07).
In conclusion, the inspectors determined that mechanical design
packages were generally acceptable for control of a facility
change or specification.
As previously stated, inconsistencies
with current plant procedures were noted that indicate additional
attention to detail in the design review process was required.
c.
Maintenance
The inspectors interviewed maintenance personnel to ascertain the
threshold for identifying equipment problems on maintenance work
requests and to determine the effectiveness of maintenance activities.
The inspectors reviewed:
Completed work orders
Maintenance procedures
Craft training
Status of corrective and preventive maintenance (PM) activities *
Control room logbooks
Licensee corrective action documents
Ongoing maintenance activities
Computer printouts of outstanding PM and Corrective Maintenance
Work Requests.
(1) Electrical Maintenance
The inspectors reviewed eleven work ord~rs of which five
pertained to ongoing maintenance activities.
The inspectors
verified that maintenance activities had been adequately
preplanned and correctly prioritized by the review and
observation of field implemented work orders.
Instructions were
appropriately detailed and applicable proce9ures were included in
the work order packages.
Also, the inspector verified that:
Applicable Technical Specification and plant conditions were
noted;
Special safety and QC requireme!1ts were noted;
8
(2)
Operability test requirements were specified;
Provisions to summarize work performed were made; and
Required administrative reviews were completed prior to
declaring the system operable.
The maintenance staff had a positive attitude and appeared to be
knowledgeable of assigned tasks.
The inspectors did identify an
anomaly in the issuance of a work order 24500885 for maintenance
of the diesel generator crankcase exhaust motor.
This work order
was originally planned and written in April 1985; however, the
work order was issued in October 1987, without a current review
by the work planner or maintenance supervisor.
As a result, the
work order package did not contain or reference two procedures
that were applicable in October 1987, but not in April 1985.
These two procedures were:
SPS-E-7, which delineated
requirements for electrical resistance tests; and MSE-E-12, which
delineated the requirements for electrical terminations~ The
crankcase exhaust motor was not resistance tested prior to
disassembly and QC was not notified to witness the test as
required by procedure SPS-E-7.
Failure to review Work Order 24500885 prior to issuance for work is an example of an
improperly planned maintenance activity.
Licensee Administrative
Procedure 5.01, "Processing Work Requests/Work Order" requires a
review of work orders by the Work Planner, Maintenance Supervisor,
and others to ensure that all necessary documents and
instructions were identified.
Failure to review Work Order 24500885 for the diesel generator crankcase exhaust motor prior
to issuance is an example of a violation of Technical
Specification, Section 6.8.1.a. (255/87027-08).
Mechanical
The inspectors reviewed four work orders for which work had
been completed in the field.
These work orders were identified
as
11open
11 pending completion of operability testing.
The
inspectors reviewed the documentation in these work packages.
Based on these reviews, no problems were identified with the
maintenance activities; however, a problem was identified in
one of the work orders that was not directly related to
maintenance activities.
Work Order 24706014, involved the
disassembly and inspection of an auxiliary feedwater motor
operated valve (M0-0743) due to excessive cycling.
The valve
cycled open and then closed continuously for at least 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />,
which exceeded the designed operations for some of the Limitorque
valve operator components.
Failure to remove a jumper, which had
been placed in the valve operator circuitry during MOVATS *testing,
caused the excessive cycling.
Failure to remove the jumper was
documented on Deviation Report (DR) No. D-PAL-87-1424, which was
issued on October 10, 1987.
The action described to prevent
9
d .
recurrence appeared to be adequate; however, during the
inspection three other problems pertaining to lifted leads and.
jumpers were identified.
See Paragraph 3.d:(3) of this report
for further details.
The inspectors also reviewed three work order packages that were
ready for work.
The work orders had the appropriate approvals,
contained adequate work instructions, applicable procedures, and
the necessary design information to perform the maintenance
activity.
The work was of acceptable quality and performed in
accordance with the work order packages.
The inspectors also
witnessed-maintenance associated with five work orders.
Maintenance personnel appeared to be knowledgeable of the work
and job instructions in the packages.
The packages contained the
necessary documents and informatfon, and no problems were noted.
The inspectors reviewed training requirements for maintenance
personnel classified as repairman A, repairman B, and welders.
Training records for five mechanical maintenance personnel were
selected for review.
During discussions with licensee personnel,
the inspectors were informed that due to union contracts,
upgrading of repairman levels to other classification levels was
based on length of service rather than training.
In some cases,
repairmen may not have completed the designated course for a
specific classification level.
To ensure that only qualified
personnel performed maintenance work, the licensee established a
qualifications system based on tasks. -During a review of a list
identifying qualified repairmen, the inspectors noted that 42 of
the*56 repairmen listed were qualified to perform more than
two-thirds of the listed task based solely on past experience.
There was insufficient time for the inspectors to review the
methods used for qualifying maintenance personnel by tasks.
This is an open item (255/87027-09).
In conclusion, the inspectors determined that corrective and
preventive maintenance activities appeared to be properly controlled:
The inspectors reviewed a report entitled
11WO Report - Count of Open
Work Order by Status,
11 dated October 28, 1987.
This report included
1,942.open maintenance work orders.
This number included 530 work
orders that were field complete, but were classified as
11 open
11 pending
completion of operability testing.
This left 1,412 open work orders
that field work had not been completed, which reflected a substantial
reduction in the number of open work orders from previous months.
In
addition, the inspectors determined that the licensee continued to
progress toward a maintenance program goal of approximately 50%
preventive maintenance.
Based on this inspection, the inspectors
concluded that maintenance activities were effectively implemented.
Operations and Systems
To assess the level of involvement by operations in maintenance, the
inspectors observed control room activities, reviewed appropriate
logbooks and status boards maintained by.the Operations Department,
10
and conducted interviews involving two shifts of operators and shift
supervisors.
System/Component inspections of the 1-1 and 1-2 Diesel
Generators (DIG) were conducted to ascertain the material condition
and to verify that appropriate work requests had been initiated to
maintain the systems operable.
The inspectors also reviewed a recent
event, loss of shutdown cooling, which occurred on October 15, 1987.
Reviews to assess the adequacy of post maintenance/modification
testing were performed for several Facility Changes, Specification
Changes, and Work Orders.
(1) Control Room Activities
(2)
The inspectors reviewed control room and shift supervisor's
logbooks, switching and tagging order logbook, current LCO status
board entries, and current equipment status board entries to
verify proper implementation of administrative procedures that
controlled removal and restoration of equipment.
The inspectors
also reviewed Administrative Procedures 4.01, "Shift Operations,
11
4.03, "Equipment Control,
11 and 5.01;
11 Processing Work Requests/
Work Orders,
11 and interviewed several plant operators and shift
supervisors to assess levels of familiarity with the requirements
contained within those procedures.
During review of the control room logbooks, the inspectors noted
that some entries appeared to be incomplete or missing.
There
were entries that documented equipment returned to an operable
status without a corresponding prior logbook entry which
documented removal of the equipment from service.
Also, there
were entries that identified the initiation of surveillance
activities, but no subsequent entries showing completion.
It
was determined that the missing entries from the control room
logbooks had been included in the shift supervisor 1s logbook,
Palisades Nuclear Plant Administrative Procedure 4.01,
11Shif;t
Operations,
11 delineates the types of entries required in each
logbook.
The control room logbook entries noted as incomplete
were required in the control room logbooks and the shift
supervisor's logbook.
This indicated an apparent weakness on the
part of plant operators to properly implement that portion of
Administrative Procedure 4.01 which addresses control room
logbooks.
The quality of logbook keeping is considered an
unresolved item (255/87027-10).
The inspectors did determine
that equipment problems noted in the control room logbooks had
been identified on work orders.
System Walkdown
The inspectors conducted a walkdown inspection of the 1-1 and
1-2 DGs to ascertain the material condition.
The inspectors were
primarily interested in fluid leaks and operability of individual
components.
The inspectors verified that all conditions
identifiable as potentially degradable to the DGs continued
11
operability had been identifie~ by plant personnel and tagged
with Component Problem Identification Tags (CPITs) .. The *1-1 OG
had 16 CPITs and the 1-2 OG had 13 CPITs on individual components
at the time of the walkdown.
The inspectors verified that each
CPIT was directly traceable to a work request initiated to
correct the particular problem and was properly prioritized.
The material condition of the OGs was determined to be acceptable.
(3) Maintenance Related Events
The inspectors reviewed several events that occurred over an
eight day period which culminated in loss of shutdown cooling on
October 15, 1987.
The following is the sequence of these events:
(a)
(b)
On October 7, 1987, while MOVATS, Inc. personnel* were
performing diagnostic tests of valve M0-0798 (Auxiliary
Feedwater to Steam Generator ESOB Isolation), an electrical
jumper was inadvertently installed in the circuitry involved
with M0-0760,
This problem was detected during the test
when M0-0798 could not be locally closed at the step
required by the procedure.
The licensee subsequently
determined that the improperly installed jumper was a
result of MOVATS testing personnel being unfamiliar with
Palisades electrical drawing schemes.
To preclude
. recurrence, the licensee assigned an electrical engineer
to augment the MOVATS team and increase involvement in
MOVATS testing activities.
Upon identification of thfs
problem, plant personnel took steps to correct the
situation; however, no Deviation Report was.initiated in
accordance with Palisades Administrative Procedure 3.03,
11Corrective Action.
11
On October 8, 1987, upon completion of MOVATS diagnostic
tests, valve M0-0743 (Auxiliary Feedwater isolation
va1ve) was reenergized with an electrical jumper still
installed.
As a result, and not known to operations
personnel, valve M0-0743 cycled open and closed for 22
hours.
M0-0743 was deenergized and work orders initiated
to disassemble and inspect both the valve and operator.
Deviation Report (OR), D-PAL-87-142, was issued to document
.this event.
This OR described the event in regard to the
jumper not being removed, which resulted in the cycling of
valve M0-0743; however, the DR described the cycling as
11an extended period of time
11 instead of specifically
stating 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
The DR did not address the reason the
cycling of the valve was not identified by operations
personnel.
The inspector was concerned since valve position indicating
lights for M0-0743 operated correctly in the control room
during the approximately 2000 complete cycles from open to
close.
12
(c)
On October 9, 1987, during tests of valve M0-3080 (High
Pressure Safety Injection Mode Selection Valve) MOVATS
personnel identified that lifted leads had not been logged
by the previous shift as required by procedures.
Upon
identification, the MOVATS personnel verified that the
proper leads were lifted and documented the condition on
the
11Jumper/Lifted Wire Data Sheet;
11 however, a DR was not
issued to document the failure as required by Palisades
Administrative Procedure 3.03,*
11Corrective Actions.
11
(d)
On October 15, 1987, during diagnostic tests, an electrical
jumper was inadvertently installed in the circuitry of valve
M0-3008 (Low Pressure Safety Injection Cold Leg Isolation).
The jumper caused valve M0-3008 to begin cycling with a
resultant effect on Safety Injection pump
11A
11 discharge
pressure.
Because of a concern for pump cavitation,
operations personnel secured the pump and deenergized
M0-3008.
As a result, shutdown cooling was termin~ted for
approximately 26 minutes that resulted in an increase of
37 degrees in reactor coolant temperature.
The events described above all occurred during the diagnostic
testing of valves by a site contractor, MOVATS, Inc.
In response,
the licensee took steps to correct the specific problem(s)
identified in each case; however, corrective actions to raise
the overall level of licensee control of this contractor's
activities were untimely as shown by the continued events.
This
failure to take timely corrective action to preclude repetition
is considered an example of a violation of 10 CFR 50, Appendix B,
Criterion XVI (255/87027-018).
During review of the above events,
the inspectors identified the following concerns that should be
included in the licensee's corrective actions:
Site contractor's activities need to be strengthened,
especially in the area of preplanning.
There is a weakness in implementation of the
11 jumper
11
program by plant personnel; licensee personnel were directly
participating with MOVATS personnel in the placing of
electrical jumpers, yet serious performance problems
occurred ..
An in-depth evaluation of the DR process should be
performed by the licensee since three of the events
identified above were either not documented or were
inadequately described on ORs.
With respect to the October 8 event, an apparent weakness ~xisted
with operator awareness of plant systems status since valve
M0-0743 cycled for approximately 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> without the cognizance
of operations personnel.
A contributing factor appeared to be
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the absence of any direct means to aid the operator_ in
ascertaining system/component status from the panels.
Currently,
to determine equipment status, operators must review logbooks and
status boards.
If some means had existed to directly identify
the status of M0-0743 at the panel, the cycling of the valve may
have been detected sooner than 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
The licensee agreed to
evaluate the inspector's concern in this area.
This is an open
item (255/87027-11).
(4) Post Modification/Maintenance Testing
The following FCs, SCs, and Work Orders (W.O.s) were reviewed
to determine if the specified post modification/maintenance
testing was adequate to ensure equipment operability.
Installation of Remote/Local Transfer Switch
and Associated Fused for Breaker 152-106.
Replacement of Atmospheric Steam Dump Valves.
Upgrade of EHC System Hydraulic Tubing and
Associate Fittings.
Replacement of MV-FW501 and MV-FW501A Vogt
Globe Valyes with Vogt Gate Valves.
Replacement of MV-3232 2 inch Velan Valve
with a 2-inch Vogt Valve.
W.O. 24704920
Investigate/Correct Stroke Time Increase on
CV-04388.
W.O. 24704922
Investigate/Correct Stroke Time Increase on
CV-0437B.
W.O. 24705607
PM for P64A (North Hotwell Sample Pump).
The inspectors determined that the post modification/maintenance
testing associated with the above FCs, SCc, and W.O.s appeared
adequate to ensure operability of the affected equipment.
One violation and an example of another violation were identified.
e.
Canel usi ons
Based on inspection activities described in this report, the
inspection team concluded:
The threshold for placing equipment problems on maintenance work
orders was sufficient to maintai'n the material condition of the
plant at an acceptable level.
This conclusion was based on
interviews, walkdown of both diesel generators, review of control
room logbooks, and review of work o~der computer printouts.
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Corrective actions for equipment problems appeared adequate and
focused towards the root. *cause.
This conclusion was based on ,
review of various corrective actions documents, cohtr61 room
logbooks, and Component Problem Identification*Tags (CPIT) for
the diesel generators.
Interviews with personnel did not
disclose any instances where rework was excessive.
Preventive Maintenance (PM) was progressing towards the desired
goal of approximately 50% of the maintenance activities; This
conclusion was based on a review of computer listing of PMs, an
interview with the Mechanical Maintenance Supervisor and a review
of a computer listing of overdue PMs.
Availability and accuracy of mechanical design documents were
generally acceptable to support the processing of mechanical
modification packages; however, management attention is
required to ensure that electrical drawings are revised to
reflect future modifications.
Additional management involvement
is necessary in this area.
Except .for this particular weakness,
the team concluded that the electrical modification activities
had improved since the last NRC inspection in this area.
The training program for maintenance personnel appeared to be
effectively implemented.
This conclusion was based on reviewing
training records for maintenance personnel and the absence of
problems while witnessing maintenance activities.
The
maintenance training program was recently accredited by INPO.
Prior planning and assignment of priorities in maintenance
activities was evident in resolving equipment problems.
Management's involvement has resulted in improving maintenance
and modification activities, thus improving the material
- condition of the plant.
Management involvement with contractor work activities needs
improvement in the area of orientation and training.
Management attention should be directed towards establishing a
more viable system for tracking and status of NRC identified
problems.
Management involvement needs improvement in the area of timely
corrective actions.
This was evident in the events preceding
the loss of shutdown cooling on October 15, 1987.
One violation and an example of another violation was identified.
4.
Open Items
Open items are matters that have been discussed with the licensee, which
will be reviewed, further, and involve some action on the part of the NRC
_or licensee or both.
Open items identified during the inspection are
discussed in Paragraphs 3.b(l), 3.b(2), 3.c(2l, and 3.d(3).
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5.
Unresolved Items
Unresolved .items are matters about which more information is required in
order to ascertain whether they are acceptable items, violations, or
deviations.
Unresolved items disclosed during this inspection are included
in Paragraphs 3.b(l) and 3.d(l).
6.
Exit Interviews
The inspectors met with licensee representatives (denoted in Paragraph 1)
on October 30, 1987, at the Palisades Plant and discussed by telephone on
December 17, 1987, and summarized the purpose (scope) and findings of the
inspection.
The inspectors discussed the likely informational content of
the inspection report with regard to document or processes reviewed by the
inspectors during the inspection.
The licensee did not identify any such
documents or processes as proprietary.
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