ML18054B409
| ML18054B409 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/24/1990 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9001310525 | |
| Download: ML18054B409 (8) | |
Text
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consumers Po war PDWERINli MICHlliAN'S PRDliRESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 January 24, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 89027 Kenneth W Berry Director Nuclear Licensing NRC Inspection Report 89027 dated September 21, 1989 noted that four apparent violations of NRC requirements were identified and that potential for escalated enforcement action was being reviewed.
Subsequently, on September 28, 1989 an Enforcement Conference was held between the NRC and Consumers Power Company at NRC Region III headquarters in Glen Ellyn, IL.
As a result 'of this meeting, two Severity Level JV violations of NRC reciuirements were issued by NRC letter dated December 18, 1989 requiring a response by January 17, 1990.
An additional 7 days to conduct management reviews of this response was requested and granted during telephone conversations with Mr Bruce L Burgess of the NRC on January 16, 1990.
Consumers Power Company's responses to the issued violations are provided in the following attachment.
The NRC letter dated December 18, 1989 additionally provided-three concerns to which a response was requested.
After review of these concerns and the violations presented, we have concluded that the concerns were a contributory factor for NRC Item 2 (89027-01).
As such, discussion relative to these concerns and corrective measures taken and/or being taken have been provided in our response to Item 2 of the NRC letter dated December 18, 1989.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Res:i_dent Inspector - Palisades Attachment OC0190-0008-NW2 9001310525 900124 PDR ADOCK 0500)2~S
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OC0190-0008-NLO/.
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 CONSUMERS POWER COMPAl\\TY'S,RE~PONSE TO INSPECTION REPORT 89027 January 24, 1990 6 Pages
1 ITEM 1 Violation (50-255/89027-02. (DPR))
10CFR50 Appendix *B Criterion XI, "Test Controls", specifies the performance of testing to show acceptable design performance, documented results and evaluation to show that test requirements are satifsied.
Technical Specification 4.1 and 10CFR50 Appendix J require periodic integrated (ILRT) and local leak rate testing (LLRT) of the containment for integrity and testing after modification of the containment.
Contrary to the above, post modification testing of a portion of the modifications performed to containment penetrations 17 and il8 in 1980 was not performed, documented and evaluated. to determine acceptability of the modification and a LLRT was not performed on a portion of the piping until July 20, 1989.
This is a Severity Level IV violation (Supplement I).
Reason For Violation Containment penetrations 17 and 48 were modified and declared operable on May 5, 1980.
These modifications were performed in response to Inspection Report 80002 dated March 6, 1980 which -identified that leakage tests were not being performed after replacement of a pipe cap which served as the licensing basis containment boundary.
The current c*onfiguration, resultant from the 1980 modification, includes a normally open instrument isolation valve, the associated pressure switch/transmitter and two manual containment isolation valves.
This configuration of double isolation is present for each of the four instrument lines passing through each penetration, eight in total.
The failure to test portions of the piping associated with penetrations 17 and 48 following the 1980 modification has been attributed to inadequate post modification testing.
Installation and testing of the modified penetrations was to be performed under six procedures.
Four of the six procedures were*
completed and documented within the modification package.
The remaining two procedures, however, were cancelled because other procedures were believed to satisfy the requirement.
The cancelled procedures would have properly tested the portions of the piping identified by this violation.
The failure to test portions of penetrations 17 and 48 under the current-ILRT and LLRT program has been attributed to a failure to identify the lack of overlap between the ILRT and the LLRTs.
The ILRT tests the pressure switch piping from the Containment Building to the instrument isolation valve and most pressure transmitters piping to the designated containment isolation valve.
The LLRT tests from the calibration test tap connection in the Auxiliary Building to the innermost designated containment isolation valve.
The piping between the instrument valve and the designated containment isolation valve was not tested for piping associated with pressure switches and some transmitters.
This testing practice has been utilized since the
.first LLRT on these penetrations was performed in 1981 and duplicates the post modification testing performed in 1980.
OC0190-0008-NL02.
2 While not formally testing the sections of piping between the instrument isolation and designated containment isolation valves for piping associated with pressure switches and some transmitters, pressures ranging from 10 to 100 psi have been imposed on the piping during monthly and refueling calibrations.
These calibrations provide good evidence that' these instrument lines were intact and did not leak.
It should be noted that while performing this monthly calibration test the leakRge present on July 19, 1989 was identified.
Corrective Actions Taken And Results Achieved During* the period from approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on July 19, 1989 (when leakage was identified) to 1955 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.438775e-4 months <br /> on July 20, 1989, procedures were developed and satisfactorily performed to verify the integrity of previously. untested portions of piping at containment design pressure.
The total leakage calcu-lated for all previously untested portions of piping was quantified to be 1290.96 cc/min which is only a fraction of the allowed 65,200 cc/min leakage.
LLRT test procedures have been instituted to provide continued testing of all piping associated with penetrations 17 and 48 in accordance with 10CFR50
- Appendix J.
A preliminary reviews of the ILRT and LLRT programs was conducted to insure all required testing is being completed.
This review was conducted utilizing existing Plant drawings and test procedures.
This review noted that a section 0f piping downstream of MV-CRW647A on penetration 25 (clean waste receiver tanks inside the Containment Building to the plant stack) was also not tested.
Subsequent evaluations* have revealed that a conscious decision was made to isolate this piping during ILRT performance to prevent over-ranging and damaging the pressure transmitter.
The section of piping jsolated was approximately eight inches in length and contains a tee type fitting.
The ILRT procedure clearly states our intentions of isolating the line. A of.this procedure contains a note stating, "The following valve is being closed to prevent over-pressurizing PT-1065".
ANSI Document N45.4-1972, Section 4.6, General Preparations for Test Pressurizing states, ".*. contents of the containment structure that are sensitive to damage by a pressure differential, or by pressures above atmospheric (such as some instruments) should be removed or otherwise protected".
The NRC has recognized this document and the industry uses it as a guide.
Our position is that isolating the pressure transmitter to prevent damage is appropriate under the "otherwise protected" genre and that no other testing of that line is required.
- However, at the time of discovery, it was decided to close the two manual isolations for PT-1065 until-final resolution was determined.
In summary, it was felt th.at this was not a similar case to penetrations 17 and 48 since we knowingly isolated the transmitter, no suitable alternate test existed and that ANSI N45.5-1972 was correctly applied.
However, for prudency, an LLRT was written and satisfactorily performed on August 1, 1989 (identified leakage was 209 cc/min) for the previously untested piping.
OC0190-0008-NL02
A review of PT-1065 functions and need was conducted.
This review concluded that since. other qualified pressure indications are available, PT-1065 has no specific purpose and should be removed.
A request for modification has been initiated to remove PT-1065.
Until PT-1065 is removed, actions to assure containment integrity is maintained have been taken.
These actions include
- changing containment integrity checkli_sts to verify isolation valves are 3
locked closed, drawing change requests were initiated to indicate the isolation valves in a normally closed position and appropriate valve tags have been placed.
The LLRr procedure developed to test the piping associated with PT-1065 will remain active until PT-1065 is removed to assure piping integrity.
Corrective Actions To Be Taken To. Avoid Further Non-Compliance A complete review 6f the ILRT and LLRT program is being conducted.
This review includes physical walkdowns of penetrations to verify accuracy of drawings and test boundaries, reviews of past modifications to penetrations to assure required test lineups were made and reviews of ILRT versus LLRT lineups to verify all required lines are tested.
Date When Full Compliance Will Re Achieved The complete review of the ILRT a~d LLRT programs as described above will be completed by August 1, 1990.
ITEM 2 Violation (50-255/89027-01 (DPR))
Technical Specification 3.6 requires containment integrity during Plant operation above-the cold shutdown condition.
Technical Specificatfon 1. 4 requires that all non-automatic containment isolation valves be closed to maintain containment integrity.
Contrary to the above:
- a.
Calibration of instrument PT-1815 and repair of the fitting leak associated with containment penetration 48 on July 14, 1989 (and other occasions) involved the disassembly of piping, resulting in the violation of containment integrity requirements.
- b.
The performance of test MI-5 at power on July 19, 1989 (and numerous*
performances since 1980) involved the opening of both designated non-automatic (manual-) containment isolation valves for penetrations 17 and 48 and violated containment integrity requirements.
This is a Severity Level IV violation.
OC0190-0008-NL02
4 Reason For Violation The Technical Specification surveillance testing of the associated containment pressure switches (penetrations 17 & 48) had been performed monthly by removing the test tap, opening the manual containment isolation valves, closing the instrument isolation valve and pressurizing the line.
This practice violated Technical Specifications Sections 1.4 and 3.6 which requires that all manual containment isolation valves be closed when the Plant is above the cold shutdown condition unless noted in Table 3.6.1.
The failure to identify this condition has been attributed to a lack of understanding of Technical Specifi-cation requirements and inadequate procedural reviews.
Procedural reviews for Technical Speci-fication surveillance procedures currently require a multi-functional review prior to implementation.
This review currently includes a technical, administrative, Quality Assurance, safety evaluation, ALARA, environmental and Plant Rev-iew Courrnittee review.
Additionally, an Operations Department review is required for all procedures which involve the Operations Department during test performance.
Specific review requirements for individual reviews are specified by procedure, including the requirement to assure that Technical Specification requirements are met.
Preliminary assessment of procedural review inadequacy indicates that potential causes include lack of; 1) a full understanding of Technical Specification requirements, 2) knowledge of specific review requirements, and 3) clearly defined expectations for reviewers.
The cause of review inadequacy is believed to be a human performance issue and remains under *evaluation for root cause.
During interviews with I&C personnel it was identified that during calib-.
rations, fittings at isolation valves were disconnected and test equipment connected.
These interviews also identi_fied the time during which integrity may have been breached to be nominally less than one-half an hour and that the instrument isolation valves are typically closed prior to piping disassembly, thereby isolating containment.
While the instrument isolation valves are _not formally classified as containment isolation valves, they are similar in critical characteristics to the designated isolation valves.
The breaching of containment integrity during the calibration of PT-1815 has been attributed to a lack of understanding of the containment isolation system, a lack of know-ledge regarding the significance of orange valve tags (designation for contain-ment isolation valves) and the purpose of test tap usage.
Additionally, the contr.olling document for the calibration of pressure switches/transmitters was a periodic activity control and calibration sheet which did not have formal proce~ural guidance detailed.
This is believed to be the cause of work scope exceeding that expected by Operations personnel.
The failure to assure uniform awareness of all requirements and controls necessary to maintain containment integrity regarding recognition of the significance of orange tags has been attributed to inadequate training for personnel whose job function may require component disassembly.
OCO 190-0008-NT,02
Corrective Actions Taken And Results Achieved Technical Specification Surveillance Procedure MI-5 has.been revised to provide pressure switch testing via an electronic signal versus applying a pressure source.
This revision precludes the need to open the designated isolation valves on a monthly basis.
Appropriate pressure source testing is already completed under another procedure on refueling periodicity. *All applicable I&C surveillance test procedures have been revised to direct pressure source connections only at test taps and not to breach containment integrity boundaries.
Additionally, these revisions have included direction for the I&C technicians to immediately notify the Shift Supervisor of any leaks on containment penetration piping, isolation valves and fittings.
5 In order to eliminate confusion as to containment isolation boundaries, ora~ge tape has been placed on containment boundaries outside the Containment Building which are tested per 10CFRSO Appendix J.
All Plant personnel have been made aware of the significance of the boundary identifications, including orange valve tag placement by notifications being published in Plant Daily Status Sheets and Weekly Information Bulletins.
This notification further informed site personnel that:
"This physical identification (along with the placement of orange valve tags sev~ral years ago on containment isolation valves) will serve as a precaution.
Workers should ask themselves, or their supervisor, or even the Shift Supervisor if he has the appropriate work authority before he starts his job on systems denoted or marked in orange.
11 Formal training will be provided to Electrical, Mechanical and I&C repair personnel as well as applicable Engineering staff.
This training will incor-porate feedback from the training sessions already provided to Mechanical and I&C personnel regarding the events of July 19, 1989.
The Plant training matrix for* the II.RT /LI.RT and CIS engineer have been modified to require formal training covering the requirements of 10CFRSO Appendix J.
Corrective Actions To Be Taken To Avoid Further Non-Compliance As indicated above. additional training will be provided to further enhance knowledge levels and awareness of containment isolation boundaries.
A review of all calibration procedures for instruments that are within containment isolation boundaries to determine if activities are being correctly implemented with respect to Appendix J and Technical Specifications has been completed and is undergoing approval.
Any procedural deficiencies identified will be promptly evaluated and resolved.
I&C calibration procedures are being upgraded to more clearly define boundaries affected.
Findings from above evaluations will be factored into a Human Performance Evaluation (HPE.S) to determine the root cause of performance problems iden-tified wjthin the surveillance procedure review and approval process.
OC0190~ooo8-NL02
Date When Full Compliance Will Be Achieved The planned training will be completed by April 9, 1990.
The approvals for the review of calibration procedures were completecl. January 18, 1990.
The HPES evaluation will be completed by April 1, 1990.
OC0190-0008-NL02 6