ML18058A423
| ML18058A423 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/01/1992 |
| From: | Hausman G, Jablonski F, Scott W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A421 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 50-255-92-04, 50-255-92-4, NUDOCS 9205070292 | |
| Download: ML18058A423 (12) | |
See also: IR 05000255/1992004
Text
- ***
- u.s. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report No. 50-255/92004(DRS)
Docket No.
50~255 . *
Licensee:
Consumers Pow~~ Company
1945 West Parnall Road
Jackson, MI 49201
Facility Name: Palisades Nuclear Generating Plant
Inspection At: Palisades Site, Covert~ Michigan
License No. DPR-20
Inspection Conducted: January 13-,17, February 12-14, and March 16, 1992 .
Insp~ctors~}.
G.
. Hausman
Also participating in the inspection
and contributing to the report was:
A .. c. Udy, EG&G Idaho, Inc.
Approved By: 1--
Inspection Summary
Section
S-/J }~2-
Date I
5-1--ctz,
Date
. Cj- I- 9 -r._
Date
Inspection on January 13-17, February 12-14, and March 16, 1992
(R~port No. 50-255/92004(DRS))
Areas Inspected: Special announced safety inspection for assessing the
licensee's implementation of post-accident monitoring instrumentation in
accordance with Regulatory Guide (RG) 1.97, Re.vision 3 and actions concerning
previously identified 10 CFR 50.49 related environmental qualification (EQ)
inspection findings (Modules 2515/087 and 62705; SIMS Number 67.3.3 (Open)) .
Results: The licensee has implemented a program to comply with RG 1.97,
contingent upon the completion of the activities identified in paragraph 4.3.
Two unresolved items wer~ identified concerning qualified isolation devices as
discussed in paragraphs 4.1.4.2-4.1.4.4. _Two violations were identified in
- 9205070292 920501
~DR _ADOCK 05000255
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the EQ followup area concerning inadequate corrective action concerning a
previously identified Notice of Violation, as discussed in paragraph 2.2, and
eight non-qualified Raychem splices inside containment, as discussed in
paragraph 3.
The inspectors concluded that the licensee has taken adequate
corrective actions to resolve seven previri~sly identified NRC findings .
2
DETAILS
1.
Principal Persons Contacted
Consumers Power.Company
- +P. Donnelly, Pl ant Safety and Licensing Di rector
+R. Corbett, Nuclear Engineering and Construction (NECO) Programs
- +R. Hamm, Instrumentation and Control (I&C) Section Head
. * R. Kasper, Maintenance Manager
- +J. Kuemin, Licensing Administrator
+R. Orosi, .NECO Manager
- +K. Osborne, Systems Engineering Manager
+V~ Petro~ Nuclear Plant Assur~n~e Department Site Supervisor
- +D. Smedley, Staff Licensing Engineer
- +K. Toner, Electrical,. l&C, and Computer Engineering Manager
U. S. Nuclear Regulatory Commission
+J. Heller, Senior Resid~nt Inspettor
+R. Roton, Resident Inspector
J
+Denotes those participating in.the site interim .exit on January 17, 1992 .
- Denotes those participating in the site interim exit on February 14, 1992.
- Denotes those participating in the telephone exit on March 16, 1992.
Other persons were contacted as a matter of course during the inspection.
2.
Licensee's Actions Regarding Previously Identified NRC Findings
2.1
(Closed) ViolBtion (255/86032-lA(DRS)):
This violation was about *55 Rosemount Model 1153 transmitters, used in various
safety system control and indication circuits,. where the EQ files did *not
specify, and thus satisfy, appropriate instrument accuracy criteria based on
the maximum error assumed in the plant safety analysis;
NRC Inspection Report
255/90005 (DRS) i dent i fi ed that the licensee* had updated the EQ files; however,
the item remained open pending r*eview by the Office of Nuclear Reactor
Regulation (NRR).
During this inspection, the inspectors reviewed all
appropriate documentation, including NRR's response- dated May 13, 1988, and*
concluded after discussion with NRC Region III management that this item is
closed.
2.2
(Closed) Violation (255/86032-02D(DRSl):
This violation was about inadequacies in the licensee's equipment
qualification files concerning maintenance, replacement of equipment,
surveillance tests and inspections necessary to preserve the environmental
qualification of EQ_equipment listed* on the Master Equipment List (MEL).
This
violation was issued using several open items as examples, such as, Open Item
3
255/86032-02(DRS), which described discrepanc*ies in the Periodic. Activity
Control Sheet (PACS) listings for Namco and Honeywell position limit.switches,
and 480/2400 Volt motors.* During this inspection, the inspectors reviewed the
appropriate documentation concerning this violation and observed that the.*
licensee had taken adequate corrective action to resolve this violation,
except for PACS X-OPS309 and X-OPS310.
Tne previously identified violation is
closed.
However, the licensee failed to revise PACS X-OPS309 (changed to
CPS457)- and X-OPS310 and associated EQ files to provide steps to analyze oil
and inspect sleeve bearings for 2400 Volt motors when the oil appeared
discolored.
The inspectors observed that the licensee had not performed the corrective
. action identified in their response to the notice of violation (NOV) dated
December 23, 1988, concerning Open Item 255/86032-02(DRS).
As a result, the
2400 Volt motor maintenance activities did not reflect the proper EQ
maint~nance requirements.
The licensee was UDaware that the corrective
actions.had not been performed and, as a result, the inspectors had to prompt
the licensee into performing the corrective action for the identified PACS
. _listings.
Failure to perform corrective action concerning a previously
identified NOV is an example of a violation of NRC. requirement 10 CFR 50,
Appendix B, Criteria XVI, which requires, that measures shall be established
to assure that conditions adverse to quality are promptly identified and
corrected (50-255/92004-0l(DRS)).
2.3
(Closed) Violation (255/8~007-0lH, -OlI and -OlJ(DRS)):
This violation identified several examples where the licensee failed to
- provide adequate design control measures for verifying and checking the
adequacy of the design.
2.3.1
255/89007-0lH and -OlI
During upgrading of the HPSI and LPSI flow instrument loops to meet RG 1.97,
Category 2 requirements (Facility Change {FC) FC-731), the following
discrepancies were .identified in the final design calculation 7906-CS-03,
Revision 9, dated December 9, 1987.
o
The seismic stress analysis assumed an incorrect center of gravity (CG),
which was not identified during the licensee'~ checking process.
The
analysis criteria required the CG of the instruments/equipment to be
considered in the ~eismic stress calculations. However, the CG of the
instruments was not considered in the seismic stress calculations.
As a
result, the forces and mbments at the rack support attachment were
inadequately calculat~d.
o
The c~lculated bending stress "fbx" of the analysis was in error
(5645 psi verses 5916 psi). This calculation error was not identified
during the checking process.
During this inspection, the inspectors verified the calculation was revised to
include the CG, the accurate bending stress "fbx" value and that analytical
results represent an acceptable as~built condition. These items are ~losed.
4
- *
2. 3 ~ 2 255/89007-0lJ
Core cooling instrumentation modification F~567 added a reactor vessel level
- monitoring system to the plant design. This FC did not address the impact of
the increased load on the inverters, bypass regulators, and battery chargers.
FC calculations were performed to analyze the impact of the increased loading
on the preferred ac bus supply.breakers, cabling to the preferred busses from
the respective inverters and on the de batteries. However, no calculations or
analyses were evident which addressed the impact on the inverters, bypass
regulator or the de system battery chargers. Therefore, the inspectors
concluded the licensee failed to employ adequate design controls since the
full impact of the increased loading was not analyzed during the design stage*
of the FC.
During this inspection, the inspectors verified the*litensee
performed an engineering analysis documenting that the inverter, bypass
regulator, and battery charger were not overloaded as a result of the
modification. This item is closed.
2.4
(Closed) Violation (255/90005-03(DRS)):
This violation was about *failure to take adequate corrective action to resolve
a previously identified violation concerning qualification of potted
- connectors used on Viking electrical penetrations. Connector insulation
- resistance measurements were not taken during the accident portion of .the EQ
test to ensure that instrument accuracy requirements were met.
The inspector
reviewed the associated work packages and determined, as of February 1, 1991,.
that all potted connectors used on Viking electrical penetrations had been
replaced with environmentally qualified connectors.
This item is closed.
2.5
(Closed) Violation (2S5/90005-04(DRS)):
.This violation was about failure to environmentally qualify auxiliary
feedwater (AFW) control circuit relays R/0727 and R/0749~ The AFW relays,
located in a harsh environment, were not included in the EQ Master Equipment
List and consequently not environmentally qualified.
The inspectors reviewed
the "Palisades Plant Equipment Qualification List," and verified the EQ list
included the AFW relays.
The licensee had also developed "EEQ File Repor.t
MISC-35;" Revision 0, *which provided qualification of the AFW relays to the
requirements of 10 CFR 50.49(k). This item is closed.
3.
Non-Qualified Cable Splices Inside Containment
Licensee Event Report (LER)91-002 dated January 28, 1991, stated Consumers
Power Company had non-qualified Raychem heat shrink tubing installed on
reactor head vent valve cabling, shutdown cooling valve cabling, and hydrogen
recombiner cabling inside containment~ Review of the LER 91-002 and
associated documentat.i on by the inspectors i dent i fi ed the fo 11 owing NRC
- concerns:
o
Eight Raychem cable splices were not qualified prior to the EQ
deadline of November 30, 1985.
o
The licensee reported this event.
However, the LER was issued
5
0
0
75 days after the event was identified as reportable.
The lice.nsee failed to perform an adequate engineering review
during a previously identified deviation report (D-QP-88~003),
which reworked splices on some of the same equipment outside *
containment, but failed to follow through and extend the review to
the containment penetrations. If an adequate engineering review
would have been performed at that time, this occurrence may have
been prevented.
The licensee failed to report the discovery of non-qualified
Raychem cable splices identified in the 1988 deviation report via
an LER.
.
Based upon the above concerns, this is an example of a violation.of NRC
requirement 10 CFR 50.49 paragraphs*(f) and (g), which requires electrical
equip.ment important to safety must be qualified by test and analysis prior to
the EQ deadline of November 30, 1985 (50-255/92004-02(DRS)).
4.
(Open) Temporary Instruction (Tl 2515/087) (SIMS No. 67.3.3)
Tfie inspectors compared the installed RG 1.97 instrumentation to the*
commitments made in licensee correspondence related to post-accident
instrumentation as described in the Palisades RG 1.97 Safety Evaluation.
Report (SER).
References used 1n the assessment were:
RG 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to
- Assess Plant and Environs Conditions During and Following an Accident,
11
-
.
Revision 3, dated May 1983.
L~tter, CPCo to NRC dated April 14, 1983.
Letter, CPCo to NRC dated September 13, 1983.
- Letter, CPCo to NRC dated April 30, 1986.
SER, NRC to Consumers Power Company (CPCo), dated October 20, 1987, with-
Technical Evaluation Report EGG-EA-6926,
11Conformarice to Regulatory
Guide 1.97: Palisades Plant," dated July 1986 prepared for the NRC by
EG&G Idaho, Inc.
.
Letter, CPCo to NRC dated January 22, 1988.
4.1
Technical Evaluation of RG 1.97 Instrumentation
The inspectors examined the following RG 1.97 variables:
Auxiliary Feedwater Flow, Category 2, Type D
Component Cooling Water (CCW) Flow to Engineered Safety Features System,
Category 2, Type D -
Containment Hydrogen Concentration, Category 1, Type A
Degrees of Subcooling, Category 1, Type A
6
High Pressure Coolant Injection Flow, Category 2,- Type D
Low Pressure Coolant Injection Flow, Category 2, Type D
Pressurizer Level, Category l, Type A
Quench Tank Pressure, Category 3, _Type D
Quench Tank Temperature, Category 3; Type D
Reactor Coolant System Cold Leg Water Temperature, Category 1, Type B
Reactor Coolant System Hot Leg Water Temperature, Category 1, Type B
Reactor Coolant System Pressure, Category 1, Type A
Residual Heat Removal System Heat Exchanger Outlet Temperature,
Category 2, Type D *
--
Status of Standby Power, Category 2, Type D
Steam Generator Level, Category 1, Type A
Steam Generator Pressure, Category 1, Type A
The inspectors reviewed the status of SER exceptions, environmental equipment
qualification. redundaricy, physical and electrical separation, power sources~
instrument range, equipment identification, equipment calibration, and system
interfaces for the above variables' instrumentation.
The inspectors
interviewed plant personnel and inspected the RG 1.97 i~strumentation in the
co_ntrol room to assess the implementation of the requirements delineated in
The following concerns were identified.
4.1.1 Calibration of-Instrumentation
The insp~ctors observed_that_of the 16 RG-1.97 variables examined,
10 instruments representing 2 RG 1.97 variables-were not included in the
licensee's calibration program.
The calibration program did not include the
- status of standby power and CCW pumps voltage, current, frequency, and watt
meters.
As identified in paragraph 4.3, the licensee stated that these
in~truments would be calibrated and ihcorporated into a periodic calibration
program by May 1, 1992.
In addition, the licensee also stated that the list
of RG 1.97 instruments would be reviewed to assure all equipment is included
in*a periodic calibration program by May 3I, I992.
4.1.2 Isolation of Pressurizer Level Channel A (Class IE) from the CFMS
The inspectors observed that the subject instrumentation channel was connected
to the Critical Function Monitoring *system's (CFMSs) non-Class IE input
termination cabinet without adequate isolation. The licensee determined that
the signal cable should have been routed to the CFMSs Class IE input
. termination cabinet to provide electrical isolation between the Class IE. and
non-Class IE circuits. During the 1992 refueling outage, the licensee
rerouted the subject signal cable to the CFMSs Class IE input termination
cabinet.
The inspectors had* no further concerns.
- *
4.1.3 Unique Identificati-on of RG 1.97 Control Room (CR) Instrumentation
The licensee did not have a unique identification method for all RG 1.97
Category I and 2, Type A, B, and C instrumentation.
CR instruments, whether*
or not a RG I.97 instrument, whose associated sensor was located in a harsh
environment were identified with a light blue label,
CR instruments, whether
or not a RG 1.97 instrument, whose associated sensor was locat~d in a mild
7
environment were primarily identified with a tan label. The operator could
not easily discern which instruments were intended for use under accident
conditions. The licensee stated, that a common designation for RG 1.97 CR .
instrument_ation would be developed, the CR instruments relabeled to provide
the unique identification, and the operators would be trained in the labe)ing
method by June 30, 1992.
4.1.4 Indeterminate Isolation
RG 1.97 states that Category 1 instrumentation- should be eledrically
independent and physically separated from each other and from equipment not
classified as important to safety. The in~pectors could not verify the use of
qualified isolation devices for Category 1 instrumentation in the following
applications:
4.1.4.1 Steam Generator Pressure Channel~ to Non-Class IE Dat~logge~
The licensee initially designated four ste~m generator pressure
instrumentation channels per steam generator to be used to monitor this
variable for the RG 1.97 program.
The inspectors observed that the isolation
interface between the channel A instrumentation and the input to the ndn-Class
JE Tennecomp datalogger did not meet the guidance of RG 1.97 for qualified
isolation.
To resolve this issue, the licensee decided to designate only two
of the four pressure channels on each steam generator as RG 1.97
instrumentation. These two channels.(B and C) meet the RG 1.97-requirements
for post-accident mo'nitoring instrumentation.
The licensee stated that the
channel A-steam generator pressure instruments will not be designated as
RG 1.97 instrumentation.
Based upon the above and discussions with SICB at
NRR, the inspectors had no further concerns.
4.1.4.2 Steam Generator Pressure Channel B to Non-Class IE Data Processor
Thi~ instrumentation channel used*IOOk Oh~ resistors for the isolation
interface. This method of isolation has not been approved by the NRC as an
acceptable form of isolation. The licensee provided documentation (letter
dated August 10, 1983), which identified the analytical analysis used to*
support the us*e of resistors as isolation devices.
However, as a result of
discussions held with SICB at NRR, the analytical analysis alone is not
sufficient to determine that the use of resistors as isolators will provide
adequate protection during a maximum credible fault. Therefore, if the
resistor circuit configuration is to be u*sed by the licensee as a method of
isolation, empirical test data must be provided that assures the ~pplication
of a maximum credible fault will not ~egrade the operation of the protected
circuit. The licensee stated that the resistor isolation configuration will
be tested and that the results of the testing will be provided t~ the NRC by
December 31, 1992.
This is considered an unresolved item pending NRC review
of the test d~ta (50-255/92004-03(DRS)).
8
- 4.I.4.3 Pressurizer Pressure Channel A to Non-Class IE Dataloqger/
Data Processor
The i~spectors observed that no isol~tion existed between the subject
channel A instrumentation and the input to the non-Class IE feedwater purity
datalogger, and non-Class IE primary instrumentation data processor;
To
resolve this concern, the licensee (during the I992 refueling outage)
installed resistor isolation.
Howev~r, as identified in paragraph 4.I.4.2,
this is considered an unresolved item (50-255/92004-03{DRS)) pending NRC
review of the test data.
4.I.4.4 Containment Hydrogen Monitor to Non-Class IE Recorder
The inspecto~s observed that t~is vatiable did not use a qualified isolation
interface. The licensee stated that test data for the Model CD-4000 isolator
would be provi.ded to establish the acceptability of this device with regard to
maximum credible faults or replace the module with a qualified isolator. The
- licensee stated, that the test data would be .submitted to the NRC by
December 3I, I992, or the isolator would be replaced during the I993 Refueling
Outage.* This is considered an unresolved item pending NRC review of the test
data or notification from the licensee that a qualified isolation device has
replaced the non-4ualified isolation interface (50~255/92004-04(DRS))~
Based upon the number of isolation problems ide!ltified during the inspectfon,
the licensee stated that a review of all RG 1.97 Category I instrumentation
would be completed by June 30, I992, to verify that adequate electrical
isolatio~ has been provided.
In addition, the licensee stated that all
intern~l ~eviews had not been completed of the Palisades design basis with -
respect to RG I.97.
As a result, the licensee stated that a letter would be
issued to the NRC by May I, I992, which identifies the planned corrective
actions with completion dates to resolve the concerns, and any additional
items which maybe identified.
4.2
Status of SER Exceptions
4.2.I Accumulator Tank Level and Pressure
As stated in the SER, the NRC is reviewing whether Category 2 instrumentation
is necessary for this variable. Resolution of this issue is pending NRC/NRR
review, with no licensee action required at this time.
4.2.2 Component Cooling Water CCCW) Flow to ESF System
The SER stated that the licensee's instrumentation identified (pump motor
current and valve position) for this variable was unacceptable.
During this *
inspection, the licensee identified the following instrumentation to monitor
CCW flow.
o
CCW pump motor current
o
CCW pump discharge pressure
o
CCW surge tank level .
9
o
o
SDC heat exchanger inlet temperature (CCW side)
The inspectors discussed-the use of the above instruments to monitor CCW flow
with SICB at NRR and the reviewing agency.
Based upon those discussions, it
was determined that use of this instrumentation meets the requirement of
Th~ inspectors had no further-concerns.
4.2.3 Quench Tank Pressure
The licensee's instrumentation was identified in the SER as needing to have
the range increased to include the design pressure of the ~uench tank.
The
range at that time ~as identified as z~ro to 25 psig.
The inspectors found a
dual range indicator with ranges of zero to 25 psig and zero to 100 psig.
The
second range includes the limiting tank design pressure and is in conformance
with RG 1.97. The inspectors had no further concerns.
4.2.4 Quench Tank Temperature
The licensee's instrumentation was identified in the SER as needing to have
the range increased.
The range at that time was identified as zero to 300°F.
- The inspectors found that the range was zero to 350~F. This range includes
the maximum expected saturation temperature of the quench tank contents.
The
inspectors had no further concerns.
-
4.2.5 Steam Generator Pressure
RG 1.97 recommended instrumentation capable of monitoring this variable with a
range of zero to 20% above the lowest safety valve setting. The licensee had
provided instrumentation with a range of zero to 1000 psig.
The lowest safety
valve setting was 985 psig {zlOOO psia).
The SER required the range to be
changed to meet the requirements of the_RG 1.97. During the ~ontrol room
inspection, the inspectors found the range of the instrumentation was zero to
1200 psia. This meets the requirements of RG 1.97, therefore, the inspectors
had no further concerns.
4.3
Licensee Activities
As a result of discussions held with the licensee, a preliminary list of tasks
for resolving the concerns identified in paragraphs 4.1.1-4.1.4 was provided
to the inspectors. This is the preliminary list of planned RG 1.97 activities
remaining to be completed:
-
May 1. 1992
Complete calibration and incorporate instrumentation used to monitor the
status of standby power and component cooling water flow into aperiodic
calibration program.
10
May 31, 1992
Complete r~view of RG 1.97 parameters to assure all equipment is
included in a periodic calibration program.
June 30, 1992
Complete review of all RG 1.97 Category 1 instrumentation to verify
adequate electrical isolation has been provided.
Complete development of the methodology for uniquely identifying
RG 1.97, Category 1 and 2, Type A, Band C variables on the main control
panels.
Complete relabeling of the RG 1.97 CR instruments to provide unique
identification.
Complete operator training concerning the RG 1.97 labeling method.
December 31, 1992
Complete testing of the lOOk Ohm resistor isolation configuration and
provide the test data results to the NRC.
Submit test data to the NRC for the Containment Hydrogen: Monitoring
System's Model* CD-4000 isol~tor to establish the acceptability of this
device with regard to maximum c"redible faults (if the module can be
successfully qualified); Otherwise, the licensee will replace the
CD-4000 isolator with a qualified isolator during the 1993 Refueling
Outage.
The licensee stated that a finalized schedule would be submitted to the NRC by
May 1, 1992, * i dent i fyi ng planned corrective actions with completion dates to
re.solve the RG 1.97 concerns.
In addition, this schedule would also identify
any additional items that are currently known as not being completed that are
required for the Palisades RG 1.97 program.
Based on the above, the inspectors discussed the inspection results with the
Instrumentation and Controls Systems Branch (SICB) at NRR and concluded that
the licensee had implemented a program to meet the requirements of RG 1.97,
Revision 3, contingent upon the completion of the activities identified in
paragraph.4.3.
The completion of these activities will be followed as Open
Item 50-255/92004-05(DRS).
5.
Unresolved Items
An unresolved item is a matter about which more information is required in
order to ascertain whether it is an acceptable item, an open item, a
deviation, or i violation. Unresolved items remaining open duritig this
inspection are discussed in paragraphs 4.1.4.2, 4.1.4.3, and 4.1.4.4.
11
~\\
- 6.
Exit Interview
The Region I II i n*spectors met with *the 1 i censee' s representatives (denoted in
paragraph 1) during the inspection period and* on January 17, February 14, and .
by telephone at the conclusion of the inspection on March 16, 1992, to
discussed the inspection findings.
The inspectors discussed the likely
content of the inspection report with regard to documents or processes
reviewed by the inspectors. The licensee acknowledged the information and did
not indicate that any of the information disclosed during the inspection could
be considered proprietary in nature.
12