ML18057A535

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Forwards Printout of post-accident Sample Monitor Upgrade Action List Completion.Two Action Items Remain
ML18057A535
Person / Time
Site: Palisades 
Issue date: 10/19/1990
From: Slade G
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9010290214
Download: ML18057A535 (17)


Text

consumers Power POW ERi Nii NllCHlliAN'S PROliRESS Palisades Nuclear Plant:

27780 Blue Star Memorial Highway, Covert, Ml 49043

.October 19, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - PASM UPGRADE ACTION LIST COMPLETION GB Slade General Manager On February 23, 1990, Consumers Power Company submitted a status report on the Post Accident Sample Monitor (PASM).

At that time, 18 of the 27 PASM upgrade items, originally submitted in our letter dated August 15, 1989, had been completed.

Since the February 23, 1990 letter, five additional actions have been completed and are identified in the attached action list. Discussion of the remaining four actions follows.

Of the remaining actions, two were previously targeted for completion during June and September 1990, and another two have been targeted for completion at a later time.

Due to higher priority work, the actions for 1990 have been delayed until the end of the current refueling outage.

We have completed all the actions necessary to assure PASM system operability.

Two of the remaining action items, which are enhancements to system operability, are scheduled for completion during the present refueling outage (upgrading the equipment data base and Q-list, and implementing vendor's recommendation for PCV-1902).

The other two remaining items which are also enhancements, (upgrade of spare parts and possible globe valve replacement) are longer term items. Completion or disposition of these longer term items will be tracked internally.

The Plant Review Committee has reviewed the PASM system operability record over the past year and concluded that following completion of the two actions in the present refueling outage that the PASM upgrade action plan can be considered complete. Therefore, further update to this action list will not be provided unless items scheduled for the refueling outage are not completed.

Changes to the attached action list, from our previous February 23, 1990 submittal, are identified by vertical lines on the right hand margin.

/6t/4 ~-----

Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment

(

9010290214 901019 I

PDR ADOCK 05000255

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  • . 1' A CMS ENERGY COMPANY II o()/

P PDC

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PASM UPGRADE ACTION LIST COMPLETION October 18, 1990 15 Pages

ITEM MODIFY UNRELIABLE COMPONENTS

  • Replace TE-1901, TE-1902

& TE-1903

  • Replace PI-1907, PI-1908

& PI-1909

  • Reduce number of swage-lok connections WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION Replace entire instrument loop with ANSI type K components.

ANSI type K thermocouple elements have increased corrosion resis-tance to sample flow and will thus have a longer life.

Replace mechanical pressure indi-cators and their diaphragms with electrical transducers and digital indicators.

Mechanical Pis have frequently gone out of calibra-tion due to rupture of the dia-phragm.

Swagelok connections are suscep-tible to developing leakage, especially in presence of high system pressures.

swagelok connections also, however, pro-vide greater ease in performing maintenance.

Need to determine locations where it would be bene-ficial to replace some of the Swagelok connections with welded components.

STATUS/RESOLUTION Completed during 1990 Maintenance Outage Completed during 1990 Maintenance Outage Completed evaluation of those Swagelok fittings most sus-ceptible to develop-ing leakage.

This was done by review-ing w.o. history from Jan. 1986 to present.

swagelok fittings upstream of PCS sample cooler were noted as source of fitting leakage on 15 of those total 17 total W.O.'s related to fitting leakage.

REFERENCE UPDATED 6/27/90 ASSIGNMENT TARGET DATE SC-89-044 TCSaarela Completed NRC Commitment/

PW08/15/89A 03 FC-841 WBS 43090 NRC Commitment/

PW08/15/89A 04 FC-868 NRC Commitment PW08/15/89A 05 RJCorbett Completed TCSaarela Completed Page 1 of 15 1.e

ITEM DESCRIPTION MODIFY UNRELIABLE COMPONENTS (cont'd)

WORI<LOAD/TCS/MAOS PASM UPGRADE ACTION LIST STATUS/RESOLUTION Completed during 1990 Maintenance Outage REFERENCE UPDATED 6/27/90 ASSIGNMENT TARGET DATE Page 2-of 15

ITEM COMPLETE INLINE MONITORING PROJECT

  • Implement changes to Dissolved Oxygen (D02)

Analyzer and Gas Chromatograph (GC).

  • Install longer piece of tubing between MV-1907 and MV-1925 to provide proper volume for undiluted sample.
  • Complete project acceptance test T-FC-676-1.

WORKLOAD/TCS/MAOS PASM UPGRADE ACTION LIST DESCRIPTION Instruments have not performed in an acceptable manner.

System was modified due to previous erratic sample volumes.

System now provides consistent sample volumes of 3! ml.

Sample volumes need to be 4 ml.

Test is needed to verify satis-factory completion of project.

STATUS/RESOLUTION After initial revised design, D02 analyzer continued to have problems.

Implemented design change (barrier) membrane added ) to D02 analyzer.

Design change was previously implemented for Gas Chromotograph (GC).

Both D02 analyzer and Gas Chromatograph (GC) are now function-ing properly.

Design has been revised to incorp-orage a 1/8" coiled sample loop.

New sample loop has been installed.

Punch list items have been completed and project acceptance Test has been signed off.

REFERENCE FC-676 w.o. 24902506 EDC-FC-676-1 (Item was added scope to inline monitoring project).

FC-676 UPDATED 1/23/90 ASSIGNMENT GGPalmisano GGPalmisano GGPalmisano TARGET DATE Completed Completed Completed Page 3 of 15

ITEM COMPLETE INLINE MONITORING PROJECT

  • Provide seal-in relays for LPSI and PCS sample valves SV-1914 and SV-1916.

Complete Chemistry Dept. Training for mod.

WORI<LOAD/TCS/MAOS PASM UPGRADE ACTION LIST DESCRIPTION (cont'd)

Change corrects previous modifications.

Need to complete training for Chemistry technicians.

STATUS/RESOLUTION Implemented design change to provide seal-in for switches.

Training needs to be performed after modification is completed to allow use of panel for training.

Chemistry Sampling Procedure (EI-7.l) has been revised.

Training for Chemistry Technicians is complete.

REFERENCE FC-676 EDC-FC-676-16 FC-676 UPDATED 1/23/90 ASSIGNMENT GGPalmisano JPaver/

TChartrand TARGET DATE Completed Completed Page 4 of 15

ITEM EVALUATE PASM DESIGN AND IMPLEMENT CHANGES AS NECESSARY

  • Compare and evaluate alternate systems and designs.
  • Verify PASM samples are consistent with NSSS samples.

WORKLOAD/TCS/MAOS PASM UPGRADE ACTION LIST DESCRIPTION Action is needed to learn more about common industry problems and solutions.

Need to interact with other utilities to learn optimum design.

Action is needed to reverify Chemistry's ability to take accurate post accident samples.

This action is based on con-servative approach to PASM evaluation (i.e. reason,for verification is not due to suspect. design).

STATUS/RESOLUTION Palisades Plant is a member of CE Owners Group for PASM Design/

Regulatory Basis Review and also member of Sentry owners Group.

Also have issued questions over NOMIS concerning reliability and upgrades of Post Accident Sampling Systems by other utilities.

So far have received several responses because of NOMIS questioner.

REFERENCE PW08/15/89A 11 Have also held telephone discussions with other utilities concerning PASM.

Will continue to carry on dialogue with other utilities in this area.

Completed May 4, 1989.

PASM/NSSS samples are consistent with each other.

UPDATED 1/23/90 ASSIGNMENT TCSaarela/

TAChartrand TChartrand TARGET DATE Completed Completed Page 5 of 15

PASM UPGRADE ACTION LIST UPDATED 10/12/90 ITEM DESCRIPTION EVALUATE PASM DESIGN AND IMPLEMENT (cont'd)

CHANGES AS NECESSARY

  • Evaluate and implement recommendations for optimizing design of PASM Components.

WORKLOAD/TCS/MA05 As a result of walkdown and review of Panel, vendor is recommending some minor design changes to enhance operation of several components.

STATUS/RESOLUTION REFERENCE ASSIGNMENT Reviewed vendor recom-NRC Commitment/ TCSaarela mendations from Sentry PWOB/15/89A 13 letter dated 5/15/89.

Couple *of items on list were previously completed.

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.

  • Replace sample needles:

Needles have been replaced.

SC-89-317 P.0.-2003-9504

  • Replace septums:

N/A Septums have been replaced as normal

.maint item by Chemistry.

Existing design of septums is adequate.

  • Revise range of conductivity cell (CE-1902):

Conductivity cell has been replaced to allow use of alternate range for cell.

FC-676 P.O. 2004-4561 w.o. 24004677 TARGET DATE 1990 Refout Page 6 of 15

PASM UPGRADE ACTION LIST UPDATED 10/12/90 ITEM DESCRIPTION EVALUATE PASM DESIGN AND IMPLEMENT (cont'd)

CHANGES AS NECESSARY

  • Evaluate concern.about loss of control air (N2) to PASM panel valves CV-1912, CV-1913

& CV-1917.

  • Consider replacing various PASM system globe valves with ball or plug valves.

WORKLOAD/TCS/MAOS CV-1912 and CV-1913 fail closed upon loss of control air.

Valves need to be open for sampling.

Need to determine what happens to CV-1917 on loss of air.

CV-1917 is new 5-way control valve.

PASM system control air is Q-Listed.

Globe valves are susceptible to developing seat leakage.

Ball or plug valves are less apt to develop seat leakage.

Nine valves should be replaced.

Also on various PASM Panel valves design for connection of stem extension and handle is inadequate.

STATUS/RESOLUTION

  • Revise setpoint for PCV-1902:

Due to subsequent input from vendor, recommended setpoint for PCV-1902 is being changed from REFERENCE SC-89-344 90 psig to 60 psig.

Specification Change is currently being revised to incorporate this change.

Part procurement for modi-fication has been completed.

Air evaluation completed.

Design for control air to PASH Panel vlvs is adequate as is.

A-PAL-89-052 ASSIGNMENT TCSaarela It has been deter-mined that no ball or plug valve is available on the market that would fulfill design rating of PASH System.

NRC Commitment/ TCSaarela PW08/15/89A 15 A-PAL-89-064 Since a better valve is not available valves will not be replaced.

TARGET DATE Completed N/A Page 7 of 15

ITEM DESCRIPTION EVALUATE PASM DESIGN AND IMPLEMENT (cont'd)

CHANGES AS NECESSARY WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST STATUS/RESOLUTION Repairs for valve handles for MV-1907 and MV-1913 have been completed.

A modified design is being considered for connection of stem and handle on various PASM Panel valves.

This modification, however, is only.

considered an enhancement and is not required for operatbility of the PASM Panel.

Disposition of modification will be tracked per A-PAL-90-064.

REFERENCE w.o. 24001015 w.o. 24000686 UPDATED 10/12/90 ASSIGNMENT TARGET DATE Page B of 15

PASM UPGRADE ACTION LIST ITEM DESCRIPTION UPGRADE TIMELINESS OF MAINTENANCE

  • Provide higher priorities Assign higher priorities for W.O.s for Work Orders of PASM and associated sampling components.

Include those W.O.s on Ops Concern~ List.

When assigning priorities Ops needs to also identify if PASM system is inoperable or not due to maintenance.

  • Upgrade spare parts for PASM system WORKLOAD/TCS/MA05 Review spare parts program for PASM and upgrade as required.

STATUS/RESOLUTION W.O.s related to inoperability of PASM are assigned as Priority 1 and put on the Ops Concerns List.

Other W.O.s in PASM system are assigned a lower priority.

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

This item is considered an enhancement to PASM operability and its dispo-sition will be tracked per A-PAL-90-063.

REFERENCE NRC Commitment PW08/15/89A 17 A-PAL-90-063 UPDATED 10/12/90 ASSIGNMENT DWKaupa TCSaarela TARGET DATE Completed N/A Page 9 of 15

PASM UPGRADE ACTION LIST UPDATED 1/23/90 ITEM DESCRIPTION UPGRADE TIMELINESS OF MAINTENANCE (cont'd)

  • Upgrade PM program for PASM Maint.

WORKLOAD/TCS/MA05 Currently 4 PMs exist for either calibration of PASM instruments or maintenance of valves, tubing and gaskets.

Vendor has informally proposed a service contract for periodic inspection and maintenance of the panel.

Use of vendor personnel to perform PM type inspections as well as completing maintenance appears to be beneficial.

STATUS/RESOLUTION Vendor provided letter on 5/8/89 with scope of activities which could be included in service contract.

REFERENCE.

ASSIGNMENT NRC Commitment/ TCSaarela PW08/15/89A 18 Contract and Purchase Contract No.

Order have been issued 39-034-3280 for Sentry Equip Corp Services.

PPAC has been approved for quarterly PM by the vendor.

Vendor has completed his first PM of the PASM Panel.

PMs will generally iriclude exercise (and review) of system, calibration of inline monitoring type eqpt, preventative maintenance of various components and verification/testing for proper operations of other components.

P.O.# CPll-7896 PCS058 TARGET DATE Completed Page 10 of 15

PASM UPGRADE ACTION LIST ITEM DESCRIPTION EVALUATE AND UPGRADE ADMINISTRATIVE RESOURCES ASSOCIATED WITH SYSTEM

  • Revise Chemistry Sampling Procedures
  • Evaluate and upgrade drawings
  • Upgrade Equipment Data Base and Q-List WORKLOAD/TCS/MA05 Chemistry Procedures need to be updated and technicians trained regarding procedure changes.

New P&ID M219 Sh 2A has discrep-ancies.

Various electrical drawings in vendor file are awkward.

During rece.nt walkdown of a PASM w.o. one electrical drawing was found to be incorrect.

Drawings should be reviewed and upgraded.

Not all PASM components are in EDB, some components are not appropriately identified (eg V-18) and others do not have Q-List Interpretations.

EDB and Q-List need to be updated.

STATUS/RESOLUTION Procedure revision was completed 5/19/89.

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.

Procedure revision for M219 Sh 2A was initi-ated on 5/18/89.

Walkdown has been completed by Configuration Control Group for PASM Panel electrical drwgs.

Drawing updates are completed.

UPDATED 10/12/90 REFERENCE ASSIGNMENT TARGET DATE Tom Chartrand Completed NRC Commitment PW08/15/89A-20 TCSaarela JAHanks NRC Commitment/ TCSaarela PW08/15/89A 21 Completed 90 Refout Page 11 of 15

PASM UPGRADE ACTION LIST ITEM DESCRIPTION EVALUATE AND UPGRADE ADMINISTRATIVE (Cont'd)

RESOURCES ASSOCIATED WITH SYSTEM WORKLOAD/TCS/MAOS Numerous system designations are used for PASM components (eg PCS, ESS, MGS, WGS).

To help define PASM system boundaries, it is highly recommended that a new system designation (eg PAS) be provided to all PASM components.

STATUS/RESOLUTION Project assigned to Configuration Control Group.

Updates of Equipment Data Base have been essentially completed.

Revised and new Q-List inter-pretations have been initiated and are currently in review process.

REFERENCE UPDATED 10/12/90 ASSIGNMENT TARGET DATE

?age 12 of 15

ITEM IMPLEMENT MISCELLANEOUS IMPROVEMENTS TO PASM SYSTEM

  • Change Sample Cask Wheels
  • Delete PI-1914
  • Change tubing configuration to PI-1900 WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION Metal wheels of sample cask marks up aux bldg floor when transporting samples to hot or grey labs.

Need to evaluate alternate design (eg rubber wheels).

Need to initiate sc to remove PI and replace with plug.

PI'S inside of panel and not accessible during 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.

Reduce length of tubing line to PI-1900 to reduce vibration on fittings.

Add tee in line to PI-1900 to provide test connection for system hydro (RC-78).

Currently test connection for system hydro is provided by removing PI-1900.

Changes would reduce wear on Swagelok fittings associated with PI-1900.

STATUS/RESOLUTION Wheels on sample cask have been replaced with wheels that have polyurethane type tread.

PI-1914 removal completed prior to 1990 Mainten-ance Outage.

Modification to be completed as part of project for re-ducing number of Swagelok connections in PASM system.

Completed during 1990 Maintenance Outage.

UPDATED 6/27/90 REFERENCE SC-89-316 NRC Commitment/

PW08/15/89A 22 ASSIGNMENT TCSaarela NRC Commitment/

TCSaarela PW08/15/89A 23 SC-89-376 FC-868 NRC Commitment/

PW08/15/89A 24 TCSaarela TARGET DATE Completed Completed Completed Page 13 of 15

ITEM PASM MAINTENANCE ITEMS e PI-1903 e PCV-1916 e MV-1932 e EC-103-1 WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION PI-1903 not responding properly.

PT-1904 needs to be replaced and calibrated.

PT is stock item, however current balance on hand is zero.

Valve is unable to throttle sample flow to value required by Chem Proc.

Need to install new PCV.

Handle rotates more than 90° (ie, handle appears to be slipping on shaft)

Complete PM for inspection and maintenance of septums and filters.

Also check and tighten any loose valve handles.

STATUS/RESOLUTION New transmitter was installed on 6/22/89.

New valve was installed on 6/21/89.

Work Completed on 9/7/89 Chemistry Technician completed PM type activity to replace 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 plug-ging and have been determined to be acceptable.

REFERENCE WO 24902329 PO 1009-3258 WO 24903286 WO 24902918 UPDATED 1/23/90 ASSIGNMENT TCSaarela TCSaarela TCSaarela TCSaarela TARGET DATE Completed Completed Completed Completed Page 14 of 15

ITEM PASM MAINTENANCE ITEMS e EC-168 WORKLOAD/TCS/MA05 PASM UPGRADE ACTION LIST DESCRIPTION (cont'd)

Replace relay module in annunciator panel for high sample temperature alarm.

Needs a replacement relay module.

STATUS/RESOLUTION Replacement relay was installed on 6/22/89.

REFERENCE WO 24802876 UPDATED 1/23/90 ASSIGNMENT TCSaarela TARGET DATE Completed Page 15 of 15