ML18054A919

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Forwards Update to post-accident Sample Monitor Sys,Per 890616 Insp Rept 50-255/89-10.Line Items Reevaluated W/ Regards to Manpower,Design Criteria & Requirement to Meet NUREG-0373 Commitments
ML18054A919
Person / Time
Site: Palisades Entergy icon.png
Issue date: 08/15/1989
From: Berry K
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8908210092
Download: ML18054A919 (16)


Text

  • General Offices: 1945 West Parnall Road. Jackson, Ml 49201 * (517) 788-1636 Kenneth W Berry Director Nuclear Licensing August 15, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

INSPECTION REPORT 89010 UPDATE Inspection Report 50-255/89010 dated June 16, 1989 requested an update to our action plan for improving Post Accident Sample Monitor System (PASM) reliability, i.e., open item 50-255/89010-03. During an August 1, 1989 telephone conversation with your staff we indicated Consumers Power Company would submit this update by August 15, 1989. The updated PASM action plan is enclosed.

Since NRC receipt of the previous PASM action plan numerous line items have been re-evaluated with regards to manpower, design criteria and the requirement to meet our NUREG-0737 commitments. This re-evaluation has resulted in the action item due dates in the attached plan.

Inspection Report 89010 also requested a description of our plans for improving Quality Assurance oversight of vendor laboratories providing radiological analysis for strontium and yttrium. The present Quality Assurance supplier qualification program requires that this laboratory be audited every three years. The most recent audit was completed in the latter part of 1988.

Findings from the audit have been satisfactorily closed and the audit was evaluated as acceptable.

Another audit has been scheduled for October 30, 1989. The audit team will include the Corporate Health Physicist as a technical specialist. The supplier qualification program will be reviewed pending the results of this audit .

  • OC0889-0102-NL04

Nuclear Regulatory Commission 2 Palisades Plant Inspection Report 89010 Update

  • August 15, 1989 The inspector who conducted Inspection Report 89010 expressed a concern regarding our review of vendor analyses. Normal radwaste samples analyzed by the vendor are checked by a monthly surveillance required by Health Physics Procedure 10.01.

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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0889-0102-NL04

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PASM UPGRADE ACTION LIST

  • August 15, 1989
  • OC0889-0102-NL04 13 Pages

PASM UPGRADE ACTION LIST UPDATED 8/15/89

  • ITEM MODIFY UNRELIABLE COMPONENTS DESCRIPTION REFERENCE ASSIGNMENT DUE.

DATE

- Replace TE-1901, TE-1902 Replace entire instrument loop SC has been ini- SC-89-044 TCSaarela 1990

& TE-1903 with ANSI type K components. tiated. Parts Maint ANSI type K thermocouple elements are being procured. Out, have increased corrosion resis-tance to sample flow and will thus have a longer life.

- Replace PI-1907, PI-1908 Replace mechanical pressure indi- Engineering now FC-841 RJCorbett 1990

& PI-1909 cators and their diaphragms with in progress. WBS 43090 Maint electrical transducers and digital Outage indicators. Mechanical Pis have frequently gone out of calibra-tion due to rupture of the dia-phragm.

- Reduce number of Swage- Swagelok connections are suscep- Completed evaluation TCSaarela 1990 lok connections tible to developing leakage, of those Swagelok Maint especially in presence of high fittings most sus- Out system pressures. Swagelok ceptible to develop-connections also, however, pro- ing leakage. This vide greater ease in performing was done by review-maintenance. Need to deterraine ing w.o. history locations where it would be bene- from Jan. 1986 to ficial to replace some of the present. Swagelok Swagelok connections with fittings upstream of welded components. PCS sample cooler were noted as source of fitting leakage on 15 of those total 17 total w.o. 's WORKLOAD/TCS/MA05 Page 1

PASM UPG~ION LIST UPDATED 8/1~

DUE.

ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE MODIFY UNRELIABLE COMPONENTS (cont'd) related to fitting leakage. ESSR and project record were generated on 5/4/89 to replace those Swagelok fittings with welded fittings.

. WORKLOAD/TCS/MAOS Page 2

PASM UPGRADE ACTION LIST UPDATED 8/15/89 ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT COMPLETE INLINE MONITORING PROJECT

- Implement changes to Instruments have not performed After initial FC-676 GGKennedy 9/15/89 Dissolved Oxygen C00 2 l in an acceptable manner. revised design, Analyzer and Gas 00 2 analyzer Chromatograph (GC).

  • continued to have problems. Vendor continuing to evaluate design changes needed to make D0 2 analyzer work properly.

Design change has been implemented for Gas Chromotograph (GC).

w.o. 24902506

- Install longer piece System was modified due to Design has been EDC-FC-676-1 GGKennedy 10/1/89 of tubing between previous erratic sample volumes. revised to incorp- (Item was MV-1907 and MV-1925 System now provides consistent orage a 1/8" added scope to provide proper sample volumes of 3) ml. coiled sample loop. to inline volume for undiluted Sample volumes need to be 4 ml. New sample loop monitoring sample. has been ordered. project).

Delivery is expec-ted in mid September.

- .Complete project Test is needed to verify satis- Only punch list FC-676 GGKennedy 10/15/89 acceptance test factory completion of project. items remain to T-FC-676-1. be completed.

- Provide seal-in Change corrects previous Work was tempor- FC-676 GGKennedy 9/15/89 relays for LPSI modifications. arily suspended. EDC-FC-676-16 and PCS sample Work now being valves SV-1914 and resumed.

SV-1916.

WORKLOAD/TCS/MA05 Page 3

P~1SM U~TION LIST UPDATED 8/15/8 DU ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE COOPLETE INLINE MONITORING (cont'd)

PROJECT Complete Chemistry Need to complete training for Training to be FC-676 JPaver/ 1/1/90 Dept. Training Chemistry technicians. performed after TChartrand for mod. modification is completed. This will allow use of panel for training. Proc-edure for PASM operation will also be revised at that time.

WORKLOAD/TCS/MAOS Page 4

UPDATED ::~

ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE EVALUATE PASM DESIGN AND IMPLEMENT CHANGES AS NECESSARY

- Compare and evaluate Action is needed to learn more TCSaarela/ 12/31/89 alternate systems and about common industry problems TAChartrand designs. and solutions. Need to intPract with other utilities to learn optimum*design.

- Verify PASM samples are Action is needed to reverify Completed May 4, 1989. TChartrand Completed consistent with NSSS Chemistry's ability to take PASM/NSSS samples are samples. accurate post accident samples. consistent with each This action is based on con- other.

servative approach to PASM evaluation (i.e. reason for verification is not due to suspect design).

- Evaluate and implement As a result of walkdown and Reviewed vendor recom- TCSaarela 6/31/90 recommendations for review of Panel, vendor is mendations from Sentry optimizing design of recommending some minor letter dated 5/15/89.

PASM Components. design changes to enhance Couple of items on list operation of several have been completed.

components. In addition, a couple of the recommendations are included as separ-ate items on this action list. Following other changes were determined to be ap-propriate to implement (Specification Changes need to be initiated for these items):

WORKLOAD/TCS/MAOS Page 5

PASM UP CTION LIST ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT EVALUATE PASM DESIGN AND IMPLEMENT (cont'd)

CHANGES AS NECESSARY

- Replace sample needles

- Replace septums

- Revise range of conductivity cell (CE-1902)

Also still need to consider revising N2 pressure reqd for purging undiluted sample lines.

- Evaluate concern about CV-1912 and CV-1913 fail closed Air evaluation A-PAL-89-052 TCSaarela Complete loss of control air upon loss of control air. completed. Design (N 2l to PASM panel Valves need to be open for sampling. for control air to valves CV-1912, CV-1913 Need to determine what happens to PASM Panel vlvs is

& CV-1917. CV-1917 on loss of air. CV-1917 adequate as is.

is new 5-way control valve. PASM system control air is Q-Listed.

- Consider replacing Globe valves are susceptible TCSaarela 1990 various PASM system to developing seat leakage. Determination has Ma int globe *valves with Ball or plug valves are less completed on valves Outage ball or plug valves. apt to develop seat leakage. which should be Globe valves, however, provide replaced. Nine better throttling capability. valves should be Need to determine which valves replaced.

should be considered for change-out. Energy Supply Services Request (ESSR) has been initiated to effect completion of modification.

WORKLOAD/TCS/MAOS Page 6

PASM UPGRADE ACTION LIST UPDATED 8/15/89

  • ITEM DESCRIPTION UPGRADE TIMELINESS OF MAINTENANCE STATUS/RESOLUTION REFERENCE ASSIGNMENT

- Provide higher priorities Assign higher priorities for W.O.s W.O.s related to DWKaupa Completed for Work Orders of PASM and associated sampling inoperability of components. Include those W.O.s PASM are assigned on Ops Concerns List. When as Priority 1 and assigning priorities Ops needs put on the Ops to also identify if PASM system Concerns List.

is inoperable or not due to Other W.O.s in PASM maintenance. system are assigned a lower priority.

This has been in effect since 5/1/89.

- Upgrade spare parts Review spare parts program £0~ Energy Supply TCSaarela 8/1/90 for PASM system PASM and upgrade as required. Services Request (ESSR) initiated on 5/19/89 to effect upgrade of PASM system spare parts program.

- Upgrade PM program Currently 4 PMs exist for either Vendor provided TCSaarela 1/1/90 for PASM Maint. calibration of PASM instruments or letter on 5/8/89 maintenance of valves, tubing and with scope of gaskets. activities which Vendor has informally proposed could be included a service contract for per.'..,)dic in service contract.

inspection and maintenance of Completed review of the panel. vendor letter.

WORKLOAD/TCS/MAOS Page 7

PASM ~TION LIST DU ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE UPGRADE TIMELINESS OF MAINTENANCE (cont'd)

Use of vendor personnel to ~erform Vendor to perform PM type inspections as well as PM on PASM Panel completing maintenance appears to starting in January be beneficial. 1990. PMs to include exercise (and review) of system, calibra-tion of inline moni-*

toring type eqpt, preventative maint.

of various components and verification/

testing for proper operations of other components. Need to develop contract and issue Purchase Order.

WORKLOAD/TCS/MAOS Page 8

PASM UPGRADE ACTION LIST UPDATED 8/15/89 DU ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE EVALUATE AND UPGRADE ADMINISTRATIVE RESOURCES ASSOCIATED WITH SYSTEM

- Revise Chemistry Chemistry Procedures need to be Procedure revision Torn Chartrand Completed Sampling Procedures updated and technicians trained was completed 5/19/89.

regarding procedure changes.

Procedures will also be revised upon completion of inline monitoring project.

Technicians will be trained on inline monitoring mod at that time. See action under "Complete Inline Monitoring Project" for followup.

- Evaluate and upgrade New P&ID M219 Sh 2A has discrep- Procedure revision for TCSaarela P&ID Rev.

drawings ancies. Various electrical M219 Sh 2A was initi- Completed drawings in vendor file are ated on 5/18/89.

awkward. During recent war-down. JAHanks Electrical of a PASM W.O. one electrical Form 40 was written Drawings drawing was found to be incorrect. to MTNordin on 5/9/89 12/31/89 Drawings should be reviewed and requesting his action.

upgraded. Action assigned to JAHanks.

- Upgrade Equipment Not all PASM components are in EDB, Energy Supply Services TCSaarela 9/31/90 Data Base and Q-List some components are not appropriately Request (ESSR) initia-identified (eg V-18) and others do ted on 7/24/89 to no.t have Q-List Interpretations. effect upgrade using ESS EDB and Q-List need to be updated. Group.

WORKLOAD/TCS/MA05 Page 9

UPDATED 8/15/89

  • ITEM DESCRIPTION EVALUATE AND UPGRADE ADMINISTRATIVE (Cont'd)

RESOURCES ASSOCIATED WITH SYSTEM STATUS/RESOLUTION REFERENCE ASSIGNMENT Numerous system designations are Subsequently it was deter-used for PASM components (eg PCS, mined that work would be ESS, MGS, WGS). To help define better done using the PASM system boundaries, it is Configuration Control highly recommended that a new Project Group since they system designation (eg PAS) are performing similar be provided to all PASM type work on other Plant components. systems.

WORKLOAD/TCS/MAOS Page 10

PASH U~ION LIST DUE ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT DATE IMPLEMENT MISCELLANEOUS IMPROVEMENTS TO PASM SYSTEM

- Change Sample Cask Metal wheels of sample cask marks No action taken TCSaarela 12/31/90 Wheels up aux bldg floor when transporting at this time.

samples to .hot or grey labs.

Need to evaluate alternate design (eg rubber wheels).

- Delete PI-1914 Need to initiate SC to remove PI No action taken TCSaarela 1990 and replace with plug. PI'S inside at this time. Maint of panel and not accessible during Outage normal operation and or post acci-dent conditions. PI is used only for maintenance. I&C would prefer to use temporary test gauge when performing maintenance.

- Change tubing Reduce length of tubing line to Modification to be TCSaarela 1990 configuration to PI-1900 to reduce vibration on completed as part Maint PI-1900 fittings. Add tee in line to of project for re- Outage PI-1900 to provide test connection ducing number of for system hydro (RC-78). Swagelok connections in PASM system.

Currently test connection for system hydro is provided by Engineering Services removing PI-1900. Supply Request has been initiated as Changes would reduce wear on part of project to Swagelok fittings associated reduce number of with PI-1900. Swagelok connections in sample line.

WORKLOAD/TCS/MAOS Page 11

UPDATED 8/15/89 ITEM DESCRIPTION STATUS/RESOLUTION REFERENCE ASSIGNMENT PASM MAINTENANCE ITEMS

- PI-1903 PI-1903 not responding properly. New transmitter WO 24902329 TCSaarela Completed PT-1904 needs to be replaced and was installed calibrated. PT is stock item, on 6/22/89.

however current balance on hand is zero.

- PCV-1916 Valve is unable to throttle sample New valve was PO 1009-3258 TCSaarela Completed flow to value required by Chem Proc. installed on WO 24903286 Need to install new PCV. 6/21/89.

- MV-1932 Handle rotates more than 90- WO being planned. WO 24902918 TCSaarela 10/1/89

( ie, handle appears to be slipping on shaft)

- EC-103-1 Complete PM for inspection ~nd Chemistry Technician TCSaarela Completed maintenance of septums and completed PM type filters. Also check and tighten activity to replace any loose valve handles. septums and 0-rings on undiluted needle assembly. Other panel septums appear to be o.k. Chemistry has also tightened all loose valve handles.

Filters are not plugg-ing and have been determined to be acceptable.

WORKLOAD/TCS/MA05 Page 12

~----------- - - - - - - - --

-, ~M UPGRADE ACTION LIST UPDATED 8/15/89 DESCRIPTION ~TATUS/RESOLUTION REFERENCE ASSIGNMENT PASM MAINTENANCE ITEMS (cont'd)

- EC-168 Replace relay module in annunciator Replacement relay WO 24802876 TCSaarela Completed panel for high sample temperature was installed on alarm. Needs a replacement relay 6/22/89 module.

WORKLOAD/TCS/MAOS Page 13