ML18059A350
| ML18059A350 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/01/1993 |
| From: | Burgess B, Meena Khanna, Langstaff R, Lerch R, Nejfelt G, Salehi K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18059A348 | List: |
| References | |
| 50-255-93-13, NUDOCS 9309090031 | |
| Download: ML18059A350 (11) | |
See also: IR 05000255/1993013
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report No~ 50-255/93013(DRS)
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
1945 West Parnall Road
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection AT:
Palisades Site, Covert, MI
Inspection Conducted:
June 14 through July 30, 1993
Inspectors: ~~
G?:Nej
~4/.it
Tu.\\L_ \\~Cd
M. Khanna
Approved By:~..-...--
. L.
urges
C 1ef
Operational Programs Section
Inspection Summary
. Date/
61/1 /Ci3
Date
.'
Date' /
Inspection on June 14 - 18, 1993 and July 26 - 30, 1993 (Report
No. 50-255/93013CDRSl)
.
Areas Inspected: * Routine, unannounced inspection by Region III personnel of
the peer inspection process that replaced the traditional quality control (QC)
for maintenance activities (NRC Manual Chapter No. 62702) .
930909003 i 930903
~,,
ADOCK 05000255
G
PDRi:_
Inspection Summary
2
Results: One violation was identified involving the limited application of
inspections for maintenance activities in Paragraph 3.
One unresolved Item
was identified regarding design control for an improperly installed electrical
breaker that caused an inadvertent emergency diesel generator start in
Paragraph 8.
Conclusions drawn from these findings are presented in
Paragraph 2 .
DETAILS
1. _. _ Exit Meeting Attendees
Consumers Power Company CCPCo)
G. B. Slade, Plant General Manager
R. B. Kasper, Maintenance Manager
R. D. Orosz, Nuclear Engineering and Construction Organization (NECO)
Manager
K. M. Haas, Radiation Services Manager
R. M. Rice, Nuclear Performance and Assessment Department (NPAD)
Director
L. J. Ross, Mechanical Maintenance Superintendent
C. M. Grady, Maintenance Administrative Superintendent
J. Haumersen, Electrical Maintenance Superintendent
P. J. Sondgerata, NECO Superintendent
S. T. Parks, Plant Mechanical Maintenance Supervisor
G. Watkins, Plant Electrical Maintenance Supervisor
J. Kuemin, Palisades Licensing Administrator
U. S. Nuclear Regulatory Comm\\ssion CNRCl
M. E. Parker, Senior Resident Inspector, Palisades, DRP
D. G. Passehl, Resident Inspector, Palisades, DRP
.2.
Inspection Overview
The objectives of this inspection were to evaltiate the peer inspection
process, as implemented by the quality verification program, and to
review the relationship recent events had, if any, with the peer
inspection process.
The inspectors used around the clock field
observations, interviews, and n~mero~s document. reviews to accomplish
- * -these objectives.
- *
The inspectors concluded that:
~
Many maintenance activities were not inspected, as required,
due to the non-conservative interpretation of regulatory
requirements.
As a result, a violation of 10 CFR Part 50,
Appendix 8, Criterion X, "Inspection," was identified.
~
The licensee specifically limited the peer inspection process to
maintenance related activities. Contractor refueling work was
outside the scope of the peer inspection process.
The peer inspections were effective, dynamic and self-
correcting.
Both management and workers supported the peer
inspection process .
3
- "I *
The following three recent events were not a consequence of
the peer inspection process: (1) an inadvertent diesel
generator start, (2) local leak rate test failure following
maintenancer and (3) removal of a control rod while raising
the reactor vessel head.
Also, the role played by the Nuclear Performance and Assessment
Department (NPAD) to establish the peer inspection process is discussed.
3.
Regulatory Requirements and Peer Inspection Process
The quality verification program was outlined in Administrative
Procedure No. 5.23, "Quality Verification Program," dated
February 26, 1993.
Procedure No. 5.23 described three types of work
verifications: (1) worker verification, (2) double verification, and
(3) independent verification. Of these verifications, only independent
verifications satisfied the regulatory requirements for inspections.
Although Procedure No. 5.23 correctly defined each type of verification,
the procedure did not sufficiently explain that only independent
- verifications could be used to satisfy regulatory requirements for
inspections.
The inspectors interviewed several engineers, who had been
trained on using the quality verification program.
Of the four
engineers interviewed, two engineers incorrectly believed .that any
verification method could be used to satisfy a regulatory inspection
requirement.
Both of these engineers were familiar with the procedure*
and had used it for their work.
Fortunately, the licensee had opted to
use independent contract inspectors to verify the work specified by
these engineers.
Attachment 1 to Procedure No. 5.23 specified the maintenance work
activities requiring independent verification. The work activities
specified .were consistent with the licensee's non-conservative
interpretation of regulatory requirements for inspection. Consequently,
the listing -0f activities was hon-conservative.
The basis for those
activities listed were inspections either required by code requirements,
such as, the American Society of Mechanical Engineers (AMSE} or the
licensee's determination that an error could significantly affect
nuclear safety. The licensee's basis was far less conservative than
that specified by 10 CFR Part 50, Appendix B, Criterion X, "Inspection,"
which states that a program for inspection shall be established for
safety-related activities affecting quality.
Attachment 2 to Procedure No. 5.23 listed maintenance activities, for
which verifications should be considered.
Consequently, maintenance
activities used "worker verification" or "double verification" in lieu
of an "independent inspection." The inspectors noted that Attachment 2
listed many activities, such as leveling and alignment, requiring
regulatory inspections. Various industry construction standards
committed to by the licensee, such as ANSI N45.2.8, specified activities
4
.,,; *
for which inspections are to be performed.
Consequently, the inspectors
considered many of the activities listed in Attachment 2 to Procedure
No. 5.23 to require "independent verifications" for safety-related
_applications.
Both work and double verifications were worker's self-checks and did not
satisfy regulatory requirements for inspections, because they were not
independent.
Independent verifications were not consistently performed
for maintenance activities as required.
The licensee's interpretation
was that inspections were not required for many maintenance activities,
such as, torquing and alignment for safety-related equipment.
Regulatory inspection requirements are found in 10 CFR Part 50,
Appendix B, Criterion X, and in the licensee's program, CPC-2A, "Quality
Program Description for Operational Nuclear Power Plants," dated
June 15, 1993.
10 CFR Part 50, Appendix B, Criterion X, requires
mandatory independent inspection hold points if an activity affecting
quality cannot be directly monitored.
CPC-2A, Quality Program
Description for Operational Nuclear Power Plants, dated June 15, 1993,
is the licensee's quality assurance program which implements the
requirements of 10 CFR Part 50, Appendix B.
~ection 10 of CPC-2A
states, "Activities affecting the quality of safety-related structures,
~
systems and components are inspected to verify their conformance with
requirements.
Inspections are accomplished by independent verification
or process monitoring as necessary." Section 10.2.2 further states,
"Inspections are applied to procurement, maintenance, modification,
testing, fuel handling and inservice inspection to verify that items and
activities conform to specified requirements." Section 10.2.2 also
states, "Independent verification is performed at each operation where
it is necessary to verify conformance with requirements."
CPC-2A,
Appendix A, commits the* licensee to several regulatory guides and
industry standards.
To implement the requirements of 10 CFR Part 50, Appendix B,
Criterion X, the li.censee committed to Regulatory Guides 1.33 and 1..116.
A summary of these Regulatory Guides is:
NRC Regulatory Guide 1.33, Quality Assurance Program Requirements
(Operation). dated February 1978, endorses American National
Standards Institute (ANSI) NlB.7-1976, "Administrative Controls
and Quality Assurance for the Operational Phase of Nuclear Power
Plants." Section 5.2.17 of ANSI Nl8.7, "Inspections," states
"Inspections, examination, measurements, or tests of material,
products, or activities shall be performed for each work o~eration
where necessary to assure quality.
Such inspections shall be
performed by qualified individuals other than those who performed
or directly supervised the activity being inspected." The
inspectors noted that the standard considered both work functions
associated with normal operation of the plant and routine
maintenance to be activities to which an inspection program should
be applied. Although Section 5.2.7 of ANSI Nl8.7, "Maintenance
and Modifications," references various industry standards, such as
5
ANSI N45.2.8, for modification activities, ANSI Nl8.7 discusses
the applicable sections of such standards for maintenance
activities.
AND
NRC Regulatory Guide 1.116, Quality Assurance Requirements for
Installation, Inspection, and Testing of Mechanical Equipment and
Systems, dated May 1977, endorses ANSI N45.2.8-1975,
"Supplementary Quality Assurance Requirements for Installation,
Inspection, and Testing of Mechanical Equipment and Systems for
the Construction Phase of Nuclear Power Plants." Regulatory Guide
. 1.116 specifically states, "Although ANSI N45.2.8-1975 is entitled
"Supplementary Quality Assurance Requirements for Installation,
Inspection, and Testing of Mechanical Equipment and Systems for
the Construction Phase of Nuclear Power Plants,' the requirements
included in the standard are considered to be applicable during
the operations phase as well as the construction phase and should
be followed for those applicable operations phase activities that
are comparable to activities occurring during the construction
phase." Section 4.4 of ANSI N45.2.8, "Inspection," states,
"Inspections of the work areas and the work in progress shall be
performed to verify that mechanical items are being located,
instal.led, assembled or connected in compliance with the latest
approved-for-construction drawings, manufacturers' instructions,
codes, installation instructions and procedures." Section 4.4 of
ANSI N45.2.8 further states that "leveling and alignment" is an
item for which inspections shall be performed, as appropriate.
The inspectors noted that cpC-2A outlined in its Appendix A, Part 2, an
exception to the licensee's commitment to Section 2.9 of ANSI N45.2.8
which limited the applicability of Section 2.9, "Prerequisites, to
modifications of mechanical equipment."-. However, this exception only
applied to prerequisites and did not limit the applicability of the
~ection 4:4 of ANSI N45.2.B which applied to inspections.
-
The licensee acknowledged that their commitments to industry
construction standards, such as ANSI N45.2.8, applied to the operational
phase.
However, the licensee considered the inspections required by
ANSI N45.2.8 to apply only to modification activities. The licensee did
not consider such inspection requirements to apply to maintenance
activities. The inspectors disagreed with the licensee's interpretation
that the inspection requirements specified by industry construction
standards only applied to modification activities.
The licensee's rationale for their interpretation was that outside
contractors were often used for modification activities.
As such,
inspections were required.
However, most maintenance work was performed
by plant personnel.
Due to the greater familiarity with the plant
procedures and equipment, and what the licensee considered to be a
higher degree of competency, the licensee felt that the inspection
requirements of industry construction standards did not apply to
6
maintenance work performed by plant personnel.
The licensee also believed that CPC-2A had an exception to their
_commitments which stated a graded approach would be taken with respec:t**
to quality assurance requirements.
The exception referenced by the
licensee was Paragraph 20b of Part 2, Appendix A to CPC-2A.
The
inspectors noted that the particular exception referenced only applied
to Regulatory Guide 1.29, "Seismic Design Classification," dated
September 1978.
The inspectors did not consider the exception to have
any bearing upon inspection of maintenance activities.
On June 16, 1993, the inspectors observed two mechanics perform the
coupling alignment for the auxiliary feedwater turbine and pump, K-8,
using permanent maintenance procedure, "Auxiliary Feedwater Turbine
Maintenance," FWS-M-6, dated June 14, 1993.
As part of the alignment
work, the mechanics replaced the shims underneath the pump thereby
affecting the turbine to pump coupling alignment.
One of the two
mechanics, who performed the alignment, also performed the inspection of
the alignment, and accepted the alignment as satisfactory.
As described
by the quality verification program, the inspection was performed using
a double verification instead of an independent verification. This was
typical of all safety-related pump alignments.
The inspection of the
pump alignment by an individual, who performed the alignment, is
considered an example of a violation of 10 CFR Part 50, Appendix B,
Criterion X,
.
11 Insp~ction,
11 (50-255/93013-0l(DRS)).
4.
Peer Inspection Process
The peer inspection process worked in its limited application for
maintenance related activities, because of the positive involvement of*
both management and workers.
Individual elements of the peer inspection
process, such as, feedback and assessment of work quality, are discussed
below.
The quality *veri fi cation inspectors (QVI s) demonstrated independence. in
the peer inspections. The inspectors observed the independent
verifications for valve rework on the boric acid outlet check valve and
for steam trap pipe welding.
Also several examples of "double
verification" that were performed by workers performing a task, such as
for the auxiliary feedwater pump and turbine.alignment, were observed.
The Nuclear Performance and Assessment Department (NPAD) provided
mechanisms to evaluate the independence of the peer inspection process.
"Quality Verification Program," Procedure No. 5.23, Revision 0,
Section B~4.4, outlined how a peer verifier's concern for an inadequate
or inappropriate condition would ultimately be forwarded by NPAD.
Also,
NPAD performed work quality "spot check" to comply with their sampling
of the peer inspection process.
7
The peer inspections afforded a dynamic process.
In January 1993, the
mechanical maintenance supervisor added two independent inspection peer
inspection points and 21 additional double verifications for safety-
related work; and added nine double verifications for non-safety-related
- -work.
In a similar period in January 1991, no mechanical maintenance
hold points or notification points were added using the traditional
quality control organization. Also, the peer inspection process added
cleanliness inspections closing out chemical addition pump and
transmitter work.
However, these verifications would have been
established as independent inspection points, if the interpretation of
ANSI 45.2.8 was applied conservatively.
Action Item Requests (AIRs) and work requests (WRs) were also used to
provide feedback for work quality items.
During the alignment of the
auxiliary feedwater pump and turbine, an AIR and a WR were initiated
based upon comments by the inspectors.
An AIR was initiated on
June 16, 1993, to evaluate the use of equipment hold-down bolt torquing
requirements after alignment of equipment coupling.
With milled hold-
down mounting bolts and the tolerances specified (i.e., 0.001 inch),
torquing the mounting bolt became important.
Also, the licensee wrote a
WR to remove Unistrut
11 channels from the I-beam trolley above the
auxiliary turbine feedwater pump.
This channel unnecessarily restricted
trolley movement to lift the pump.
In the interviews conducted among workers, foremen, and
supervisors, the common and principal strength of the peer process
was the QVl's technical knowledge.
Contracted .weld and valve QVIs
for this outage typically had more than ten years of experience.
These experts were examined by their supervisors prior to the
start of work at Palisades to verify their competency and their
familiarity with the Peer Inspection Process.
The peer inspectors' technical competency was based upon work experience
and on-the-job-training (OJT).
The workers who perform~d the "doubl~
verification" for crimping electrical connections and* for optically
aligning equipment mechanical couplings were knowledgeable.
Additionally, the inspectors reviewed two examples when the independent
verifiers rejected unsatisfactory work for use of a valve seat and
torque wrench.
Maintenance peer inspection observations resulted in engineering
assistance.
Two examples were the engineering staff re-evaluated the
criteria for equipment cleanliness and equipment spacer dimensions.
No violations or deviations were identified in this area .
8
5.
Audits of Peer Inspection Process
The transition from the Nuclear Performance and Assessment Department
(NPAD) to the peer inspectjon process for maintenance activities was
accomplished in three phases.
In Phase One (June and July 1992), both
NPAD and peer inspectors independently assessed maintenance work.
In
Phase Two (August to December 1992), NPAD transitioned to observing 100%
of peer inspections. Because of the successes of Phases One and Two,
NPAD was sampling peer inspections in Phase Three (January 1993 to
Present).
In July 1993, a Joint Utility Management Assessment (JUMA) audit
specifically evaluated the peer inspection process. This audit
identified minor administrative problems, such as, consistently rev1s1ng
procedures to reflect the Corporate Health Specialist's role in ihe peer
inspection process.
The inspectors reviewed the instrument error criteria in several
maintenance procedures to determine the scope of corrective action taken
for a finding in the JUMA audit.
The inspectors found that the error
analysis using the square root of the sum of the squares method was used
appropriately in the calculations for the pressurizer level channel
calibration and for safety injection tank pressure channel calibration.
No violations or deviations were identified in this area.
6.
Work Quality
Management quantitatively evaluated work quality.
As an example,
the licensee chose not to re-hire a valve vend6r for the cu~rent
outage based on ~ review of valves requiring rework due to poor
. contractor quality work during the previous outage. A noteworthy
application of the peer inspection process was its use in root
cause determination to correct leakage from a boric acid outlet
--check*valve;
An additional independent inspection was establish~d
to verify that the valve bo~y seating surface and hinge pin gasket
~ere correctly installed. This inspection resulted in the
identification of an incorrect gasket material of soft carbon
steel rather than Type 304 stainless steel. The inspector further
verified that the gaskets in question were removed from stock for
this use and that receipt inspection requirements were added to
verify part numbers and gasket hardness to avoid recurrence.
No virilations or deviations were identified in this area.
7.
Recent Events
The inspectors reviewed the association of several recent site events
with the peer inspection process.
In each case, these events were not
9
within the scope of the peer inspection process.
For example, the
refueling activities discussed in NRC Inspection Report No. 50-255/93016
were intentionally excluded from the peer inspection process by the
licensee until confidence in the process was ~stablished.
The inspectors also looked at Event No. E-PAL-93-020 involving an
inadvertent emergency diesel generator start. Because of a human
factors concern to have the spare breaker contacts correspond to the
breaker contacts in use, the spare breaker was replaced by a work
request as a "like-for-like" tomponent replacement.
However, when the
new spare breaker was racked in, the breaker in service tripped. This
de-energized Bus IC and started the diesel generators. It was later
determined that internal wiring of the replacement spare breaker was
different. This was not a problem associated with the peer inspection
process.
To address the design control error associated with this
event, Unresolved Item (URI) No. 50-255/93013-02(DRS) is opened pending
a licensee's root cause ~valuation.
The last event reviewed was an emergency notification phone call made on
June 29, 1993.
This call was made because a containment penetration
control valve failed its post-maintenance local leak rate test (LLRT).
These valves provided the isolation for a 3-inch radioactive waste
system line for the clean waste receiver tank. Maintenance work was
performed on the actuator with the slower stroke time.
At no time
during this work was the piping system opened.
LLRT following this work
showed no change in the measured leak rate. After stroking the other
control valve, a LLRT was re-performed successfully.
The licensee
suspect~d that sediment from the bottom of the tank was responsible for'
control valve initial high leak rate. The peer inspection process
encompassed the appropriate valve actuator testing.
The above events were not the result of Palisade's peer inspection
process failures.
- 8.
Unresolved Items*
Unresolved items are matters about which more information was required
in order to ascertain whether they are acceptable items, items of
noncompliance, or deviations.
An unresolved item identified during this
inspection is discussed in Paragraph 8.
9.
Exit Meeting
The inspectors met with licensee representatives (denoted in
Paragraph 1) at the conclusion of the inspection on July 30, 1993, to
discuss the scope and findings of the inspection.
During the exit, the inspectors discussed the need to evaluate
maintenance activities, the adequate assessment of the peer inspection
process, and the non-applicability of peer inspection process regarding
recent events.
The licensee presented their interpretation of
regulatory requirements concerning what required inspections.
The
10
licensee's interpretation was contrary to the basis for the violation
cited.
However, the licensee neither accepted nor denied the violation
cited.
The licensee agreed to evaluate the issue further.
Licensee representatives did not identify any of the documentation used
during the inspection as proprietary.
11