ML18058A385
| ML18058A385 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/27/1992 |
| From: | Hausman G, Jablonski F, Schrum D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A384 | List: |
| References | |
| 50-255-92-11, NUDOCS 9205040081 | |
| Download: ML18058A385 (9) | |
See also: IR 05000255/1992011
Text
..
U. S. NUCLEAR REGULATORY COMMISSION
REGION* III
Report No.:
50-255/920ll(DRS)
Docket No.:
50-255
License No.:
Licensee:
Consumers Power company
1945 West Parnall Road
Jackson, MI 49201
Facility Name:
Palisades Nuclear Plant
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
February 12-14, 25-27, March 24-27, and
April 16, 1992
Inspectors:
(-/_ > 7- 9 2__
Approved By:
D. Schru111
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Inspection on Februarv 12-14, 25-27, March 24-27, and April 16,
1992 (Report No. 50-255/9201l(DRS))
Areas Inspected: Special inspection of matters associated with
the main steam isolation valve actuator solenoid valves being
inoperable in the event of a high energy *line break due to an
inadequate design.
Portions of NRc* Inspection Procedure 62705
were used during the .inspection.
.
Results~ In December 1990, the licensee's contractor* issued a
report of an extensive environmental quaiification review that
identified a large number of discrepancies.
.The licensee failed
to start a thorough review of the report until December 1991.
As
a result of the review, the licensee identified on February 5-,
1992,*that the main steam isolation valves were inoperable due to
an unqualified electrical circuit.
Since the reactor was at 100%
pqwer, the licensee requested and received a temporary waiver of
compliance.
However, the licensee's request for*the waiver did
no.t fully disclose how the unqualified cir.cuits were identified,
the existence of a contractor's report, or the other deficiencies
identified within the report .. SubsequeJ?.tly, a number of other
9205040081 920427
ADOCK 05000255
G
Inspection Summary *
2
equipment environmental* qualification prcibl~ms were identified by
the licensee, which were reported to the NRC.as licensee event.
reports *.
Two apparent violations were identified.
Section 3.4.2 describes
problems with supplying the NRC with complete and accurate
information, and Section 3.4.3 describes problems with inadequate
corrective action .
DETAILS
1. 0
~rincipal Persons Contacted
consumers Power Company (CPCo)
- G. Slade, Plant General Manager
- D. Day, Environmental Qualification Engineer
- P. Donnelly, Plant Safety and Licensing Director
- R. Hamm, Instrumentation and Control Section Head
- J. Kuemin, Licensing Manager
- R. Mccaleb, Nuclear Program Audit Department Specialist
- K. Osborne, System Engineering Manager
- K. Toner, Electric/I&C/Computer Engineering Manager
- D. Vandewalle, Mech & Civil/Structural Engineering Manager
- R. Orosz, Nuclear Engineering Manager
U. s. Nuclear Regulatory Commission (NRC)
- M. Ring, Engineering Branch Chief, Division of Reactor Safety
- M. Gamberoni, Licensing Project Manager, by Telephone
- J. Heller, Senior Resident Inspector
- B. Jorgensen, Chief, Reactor Projects Section 2A
- R. Roton, Resident Inspector
The NRC inspectors also contacted and interviewed other licensee
personnel during the inspection.
- Denotes those present at the exit meeting held March 27, 1992.
- Denotes those present at the exit meeting held April 16, 1992.
2.0
Licensee Action on Previous Inspection Findings
2.1 (Closed) Open Item (255/87027-02) Weakness with tracking the
status_of NRC issues.
The licensee improved the ability to update the data base for
open items so that ongoing knowledge of what actions have been
completed is available.
The licensee's correspondence to the NRC
on January 28, 1988, was correct in stating that a Region III
special task *force had reviewed this system and concluded in a
May 16, 1986, report that for the intended purpose of tracking
commitments that the Correspondence Logging & Commitment Tracking
system (CLCTS) works adequately.
The special task force had
performed a spot check of 100 open items, unresolved items, and
violations from the CLCTS and compared them with records,
specifically to determine whether those classified as externally
closed were in agreement with those listed as closed in the
Region III records.
With only one exception all the remaining
items checked were accurately recorded .
No additional problems have been noted by the regional or
resident staff subsequent to the occurrence of the above
concerns.
The inspector agrees with the licensee's assessment
that this was an isolated incident.
This item is closed.
2.2 (Closed) Unresolved Item (255/87027-03) Effectiveness of the
Configuration Control Project (CCP).
The inspectors determined that Schematic Diagram E-5, Sheet 15,
Revision 5 had not been revised to incorporate modification FC-
687. The NRC stated that the effectiveness of the CCP could be
adversely affected if management attention was not given to
future modifications.
The licensee stated that this type of problem is discovered and
corrected during the revie~ pr6cess by the CCP el~ctrical drawing
verification and correction task group.
The inspector .. deterfuined
that the CCP has been effective in f~nding and correcting these
types of problems.
The licensee invested substantial time in the
review of each modification with each drawing being redlined
during its comparison to the as-built configuration in the plant.
The discrepancies were appropriately prioritized for importance
to ensure timely corrective actions for the items important to
safety.
No additional NRC concerns exist for this problem.
This
item is closed.
2.3 (Closed) Unresolved Item (255/88020-6A) Licensee failed to
take proper corrective actions when discrepancies were identified
by the* CCP team.
The licensee failed to correct and .resolve discrepancies with
approximately 300 electrical~ drawings during electrical plant
walkdown-inspections.
The licensee's corrective action was to
bring the CCP discrepancy c~tegorization and evaluation process
into agreement with the actual drawing walkdown.
The inspector
determined that the corrective actions were adequate to prevent_
the condition as described in the unresolved item.
The licensee
had made substantial progress with the CCP efforts since this
unresolved item was issued and it appeared that the majority of
the work will be completed by the end of 1992.
This item is
closed.
3.0
Inspection Results
3.1
Purpose of the Inspection
The purpose of the inspection was to review the matters
associated with the main steam isolation valve (MSIV) solenoid
actuator valves being inoperable in the event of a high energy
line break, which led to a plant shut down on February 6, 1992.
3 . 2 .
Description of Event
2
On *February 5, 1992, the, licensee determined that the solenoid
valves that actuate the MSIVs .could cause a short circuit during
a postulated high energy line break and prevent the MSIVs from
closing on demand.
on February 6, 1992, the licensee promptly
reported the problem to the NRC and requested a Temporary Waiver
of Compliance (TWOC) .
On the same dayj after determining that
the problem could not be repaired, the licensee appropriately
declared the MSIVs inoperable per Technical Specification 3.5.lf
and shut down the plant.
As described in licensee event report (LER) 92-07, "Main Steam
Isolation Valves Inoperable Due to -an Unqualified Electrical
Circuit," and as determined by the NRC this condition was caused
by:
a design deficiency involving the installation of non-
enyironmentally qualified solenoid valves;
lack of adequate isolation between Class lE and non-Class lE
circuitry; and
lack of adequate isolation between redundant Class lE
components located in different areas.
3 .. 3
Significance of Event
Although a main steam line break .in the area of concern is not
likely, the failure of the MSIVs to close during a steam line
break outside containment (the event which could disable* the MSIV
solenoid valves) is considered significant.
The MSIVs would not
fail safe, that is, electric power would be needed to actuate
solenoids to cause the mechanical operator to move and close the
Failure of the MSIVs would create the potential for a
double steam generator blow down, possible tube rupture, and
possible off-site release of radiation greater than 10 CFR 100
limits.
3. 4
Inspection Findings
3. 4. 1
Immediate Actions and Corrective Actions
On February 6, 1992, the*licensee promptly reported the problem
with the MSIV actuator solenoids to the NRC and asked for a TWOC
t6 evaluate the problem and implement 6orrective action.
After
determining that the problem could not be repaired within the
available time, -the licensee shut down the plant two weeks prior
to a scheduled refueling outage.
The MSIV solenoid problem was
reported in LER 92-07 within the 30-day limit.
On February 25, 1992, the licensee completed a detailed review of
the contractor's report, which had contributed to the finding of
the MSIV solenoid problem.
This report included approximately
3
2500 items, which resulted in about 800 discrepancies with the
majority being'documentation problems.
The inspectors reviewed
about 10% of the licensee's review of the contractor's findings.
All of those items had been appropriately reviewed for
significance.
Seven Deviation Reports (DR) -Were written for-the
most significant problems.
The inspectors reviewed the DRs for
start up concerns and-determined that the resolutions were
adequate.
The licensee made modifications or appropriately
justified why operations could resume.
The licensee's corrective
actions for the several hundred documentation problems are
projected to be completed by the end of 1992; however, initiation
of corrective actions had just recently been started.
The modification to the MSIV solenoids, which was completed
during the recent refueling outage, did eliminate the specific
component environmental qualification (EQ) problems with the.
solenoids.
The MSIV solenoids were moved from the component
cooling water (CCW) room to an electrical switchgear room, which
is in a mild environment.
The inspector reviewed the MSIV
modification package and determined that it was comprehensive and
thorough.
A detailed evaluation was made that met the
requirements of 10 CFR 50.59.
The inspectors were initially
concerned that one set of solenoid valves was located in a non-
vital area; however, following additional reviews ~y the NRC, the
location was determined to be acceptable.
The licensee's efforts to improve the EQ.program were apparent in
that EQ and modification procedures had improved during the past
few years.
The inspectors determined that the procedures
contained information that will contribute to the licensee's
compliance with EQ requirements.
However, during the review of
the licensee's corrective actions the inspectors determined that
the station EQ Technical Group was understaffed to accomplish the
necessary improvements to the electrical environmental
qualification (EEQ) list and program in a timely manner.
There
was a high turnover of EQ staff for the past 7 years and very few
of the staff held the job for more than 1 year.
The experience
ievei of the staff was very low.
The in$pectors reviewed the EQ
staff training records and concluded that EQ training had not
been comprehensive.
However, the licensee had recently initiated
improvements to the EQ training.
The EEQ list and program were
being reviewed and improved by a person trained and dedicated to
that task.
On March 11, 1992, members of the licensee's staff came to Region
III for a management meeting to discuss operability issues for
the projected April 15, 1992, restart.
The licensee stated
during the meeting that there were plans for an extensive effort
similar to the CCP program to find any remaining Eti problems in
the plant.
The licensee also stated that future EQ efforts would
be documented in a letter to NRC on April 30, 1992_.
Following
4
additional NRC review of the significant issues, there were no
additional* concerrts for plant restart. *
3.4.2
Temporary Waiver of Compliance
.. As* noted *in Section 3. 4 .1, . on February 6, 1992, _the licensee
requested that the NRC grant a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TWOC to.operate the plant
and *resolve the problem with the MSIV operator solenoids.
The
TWOC was granted based on the information provided by the
licensee and the low probability qf ri~k to *the plant.
However,
the licensee determined that the problem could not be fixed
during the TWOC time period, so the reactor was shut down 2 weeks
.*prior to. a. s'cheduleq 60 day refueling outage~
.
.
.
When the. licensee orally requested the TWOC they failed to
provide
information to the NRC.about the contractor's report,
which is discussed in Section 3.4.3. _The report contained othe~
EQ probl"ems that were potentially s*ignif icant.
The NRC' s. *
deci~ion to grant the TWOC may not have occurre~ had -the NRC
known about the additional EQ discrep~ncies~
In addition,
neither the subsequently wtitten-TWOC, nor LER 92-07, mention the
matters.discussed in the contract~r's report.
Failur~ to provide
complete and accurate information.to the NRC is an .apparent
. violation bf 10 CFR 50.9. (255/92011-0l(DRS))
.3.4.3*.
Licensee's Response to a Contractor's Review of EQ
Problems
As a result of EEQ problems the licensee initiated a contractor
review of EQ problems.
In December 19go~ the contrac~6r issued a
report to.the licensee.
The report, indicated that there.were
approximately 2500 problems*with 63'listed as potent~ally*
~ignifiqant. ~Throu~h interviews with licensee personnel, the
inspectors determined that upon rec~ipt of the report, the
licensee performe'd a cursory review of the report but found no
-apparent significant problems, so no actions were taken.
on
March 14,. 1991, the plant was returned to service following a six
- .month outage without .the iicensee having fully evaluated the
probiems in the report.
The licensee's reviewer had an item on
his "things to do iist"' to review and corr~ct the problems found
by the contractor, which he considered to be do.cumentation
discrepancies.
The report remained with the reviewer even after
-a plant staff reorganization in May 1991.
In December 1991, the repo~t w~s ~u~ned oVer to the site EQ
- improvement person for review after the CCP identified a
discrepancy that also appeared _in the contractor's rep6rt.
This
occurred 12 months after the contr~ctor's.report was issued.
On
February 5, ~992i during the review of the contractor's report,
the licensee identified the MSIV control circuitry problem.
A
short in the MSIV solenoid or circuitry due to a steam line break
in the CCW room could rerider the turbine.building solenoids
5
, ,'
inoperable. because both sets of solenoids share a common pow.er
supply.
This problem was found as a result of reviewing
schematic diagram E~238 SH.1, for the MSIVs. *The problem was
also noted in the contractor's report as a discrepancy with an
'unqualified hand switch in the MSIV operator solenoid circuit.
On Febrriary 25, 1992, the licensee b6mpleted a detailed review of
the contractor's EQ report.
As a result, DRs were written on the
following equipment: residual heat exchanger temperature
elements, pressurizer level Jnstrumentation, main steam line
radiation moriitors, component cabling water heat exchanger
- solenoid valves and position switches, and feed water system
motor operated valves.
These problems were reported to the NRC
in LERs.
As indicated in this Section, and in Sections 3.4.1 and 3.4.5, it
appears that the licensee did not perform adequate corrective
actions *to d°isp.osition EQ problems. in a timely* manner even though
the contractor's repoit contained ~vidende of EQ discrepaneies
and was available to the licensee for over 1 year~ This is an
apparent violation of 10 CFR 50 Appendix B, Criterion XVI,
Corrective Actions. (255/92011-02(DRS))
3.4.4
Background Facts on the MSIV Actuator Solenoids
In 1973, the Atomic Energy .commission -(AEC) identified a concern
with high energy.line breaks (HELB) outside containment.
The
MSIV solenoid val~es, locat~d inside the CCW room, were not
qualified for -the postulated environmental conditions*of*a break
of the main steam line which passes through this room.
The
licensee's response in "Special Report No. 6, 11 dated1973,
committed to install a redundant set of solenoid*valves outside
.the CCW room to isolate ~nd vent air from MSIV operators!. In
_1974~ a spare set of MSIV operator solenoid valves was iristalled
in the turbine building for the high energy line break conditioh.
In 1979, the licensee developed the initial EEQ list in iesp6nse
ta~RC'Bulletin 79-01.
At that time the MSIV operator solenoid
v~l~es were on the EEQ list.
Two years later, they were removed
from the EEQ list because the redundant solenoid valves were
considered to be in a non-harsh environment.
In 1984, during
reviews to meet the requirements of the EQ Rule, 10 CFR 50.49,
the licensee took credit for the MSIV operator solenoid v~lves in
the turbine building; therefore, EQ requirements-were not
considered necessary.
However, the licensee failed to evaluate
the electrical design, which did not meet the single failure
requirements.
A HELB in* the turbine building c.ould. cause. the.
solenoid valves to short circuit, blow a fuse, ~nd disable both
sets of scilerioid valves, which rec~jved voltage from the same
source.
6
\\. .
3.4.5
History of Equipment Environmental Qualification (EQ)
Problems
Numerous EQ problems have occurred at Palisades since
November 30,. 1985, when licensees were required to meet EQ
requirements and be in full compliance to 10 CFR 50.49.
In
December 1986, the NRC identified eight significant EQ
- deficiencies at Palisades.
Two violations and a civil penalty
were issued to the licensee regarding EQ problems with 55
transmitters, 38 solenoids, and 15 motor-operated valve
actuators.
A violation was issued after an inspection in March
1990 when an EQ problem was found' with two relays installed in
the auxiliary feedwater control circuitry, and action was not
taken to adequately resolve a violation identified in 1986.
In
1992, EQ problems were identified with eight electrical splices
and a violation was issued because the licensee.failed to take
adequate corrective action to resolve a previously identified EQ
problem.
In January 1989, the NRC issued Information Notice 88-
86,
Suppl~ment 1, which specifically described the adverse
conditions with solenoid valves that could be caused by high
energy line breaks.
The licensee reviewed the situation but did
not include the MSIV operator solenoid valves because they were
not on the EEQ list.
The NRC issued.numerous other Information
Notices, Bulletins, and inspection reports on EQ.
The inspectors reviewed the licensee's self-assessment ~ctivities
for the EQ area.
The inspectors found that even though the plant
had problems in the EQ area since 1985, the licensee had only
performed one EQ quality assurance (QA) audit since that time.
The audit was performed in March 1991.
This audit had been
previously evaluated in NRC Inspection Report 50-255/92003, as a
QA audit with a very limited scope.
Based on all of the previous
problems in the EQ area it appeared to the inspectors that the
audit should have been much broader in scope.
4.0
Exit Meeting
The inspectors met with the licensee at the site on March 27,
1992, for an interim exit and on April 16, 1992, for a final exit
to summarize the purpose, scope, and findings of the inspection.
A verbal summary of the inspection findings was provided to the
licensee at that time.
The inspectors discussed the likely
informational content of the inspection report with regard to
documents or processes reviewed by the inspectors during the
inspection.
The licensee did not identify any such documents or
processes as proprietary .
7