ML18059A686
| ML18059A686 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/1994 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18059A687 | List: |
| References | |
| NUDOCS 9403010023 | |
| Download: ML18059A686 (19) | |
See also: IR 05000255/1993032
Text
Docket No. 50-255
License No. DPR-20
Consumers Power Company
ATTN:
Gerald B. Slade
General Manager
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION Ill
801 WARRENVILLE ROAD
LISLE. ILLINOIS 60532-4351
,*
FEB
- -2 ~~ 1394
Palisades Nuclear Generating Plant
27780 Blue Star Memorial Highway
Covert; MI
49043-9530 * *
Dear Mr. Slade:
SUBJECT~ NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-255/93032)
This refers to the inspection conducted by Messrs. M. E. Parker and D. G.
Passehl of this office from December 17, 1993, through January 28, 1994.
The inspection included a review of authorized activities for your Palisades
Nuclear Generating* facility.
At the conclusion of the inspection, the
findings were discussed with those rnembers of your staff identified in the
~nclosed report.
Areas examined during the inspection are identified ip the report. Within
these areas, the inspection consisted of a selective examination of procedures
and representative records, interviews with personnel, and observation of
activities in progress.
The purpose of the inspection was to determine
whether activities authorized by the license were conducted safely and in
accordance with NRC
requir~ments.
Based on the results of this inspection, certain of your* activities appeared
to* be in violation of NRC requirements, as specified in the enclosed Notice of
Vi_olation (Notice).
The violation involves ineffective corrective actions to
preclude repetiti~e failures in submitting Licensee Event Reports (LER) within
thirty days as required by 10 CFR 50.73.
The untimely submittal of LERs have
occurred in April 1993, May 1992, February 1991, and November 1990.* Two of
- .these late LER submittals (November 1990 and February 1991) were previously
documented in NRC violations.
We are concerned about the violation because it
indicates some persistent failures to correct this weakness.
-
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, yo~ should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to erysure compliance with NRC regulatory requirements.
9403010023 940222
ADOC~ 05000255
G
Consumers Power Company
2
~*
In accordance with 10 CFR 2. 790 of the NRC' s "Rules of Practice," a copy of
. this letter and its.enclosures will be placed in the NRC Public Document Room.
The responses directed by this lette~ and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Enclosures:
2. Inspection Report
No. 50-255/93032(DRP)
cc w/enclosure:
David P. Hoffman, Vice President
Nuclear Operations
David W. Rogers, Safety
and Licensing Director
OC/LFDCB
Resident Inspector, Rill
James R. Padgett, Michigan Public
Service Commission
Michigan Department of
Public Health
Palisades, LPM, NRR
SRI, Big Rock Point
G. E. Grant, Riil
Consumers Power Company
2
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of
this .letter and its enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No. 96.511.
Enclosures:
2. Inspection Report
No. 50-255/93032(DRP)
cc w/enclosure:
David P. Hoffman, Vice President
Nu~lear Operations .*
David W. Rogers, Safety
and Licensing Director
OC/LFDCB
Resident Inspector, RIII
James R. Padgett, Michigan Public
Service Commission
Michigan Department of
Public Health
Palisades, LPM, NRR
SRI, Big Rock Point
G. E. Grant, RIII
bee: Public
~i
. }..1'1('11 .
I RI I I
~v
Kropp
Sincerely,
fA1u)ruJtY.- ~)viJ/n .*
- 0~
L!
Lewis F. Miller, Jr., Chief
Reactor Projects Branch 2A
Mi 11 er
Consumers Power Company
Palisades Nuclear Generating Facility.
Docket No. 50-255
License No. DPR-20
During an NRC inspection conducted from December 17, 1993, through January 28,
.1994, a violation of NRC requirements was identified.
In accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violation is listed below:
10 CFR 50, Appendix B, Criterion XV[, requires that co~ditions adverse to
quality such as failures, deficiencies, deviations, defective m~terial and
equipment, and nonconformances are promptly identified and corrected. In the
case of significant conditions adverse to quality, measures shall ~ssure that
the cause of the condition is determined and corrective action taken to
preclude repetition.
10 CFR 50.73 (a)(2)(i)(B) requires that a licensee submit a Licensee Event
Report (LER) within 30 days of the discovery of.any operation ot condition
prohibited by the plant's Technical Specifications.
Contr~ry to .the above, the licensee has failed to take effective corrective
actions to preclude repetitive failures to submit LERs within 30 days of an
event in accordance with 10 CFR 50.73.
The lice~see failed to submit an LER
within 30 days in the following instances~
1. *
An LER for an April 27, 1993 event involvirg the simultaneous
inoperability of both emergency diesel generators was required to
be submitted by May 27, 1993, and was submitted on December 23,
1993.
2.
An LER for a May 6, 1992 ev~nt involving the simultaneous
inoperability of both emergency diesel generators was required to
be submitted by June 6, 1992, and was submitted on February 10,
1994.
3.
An LER for a February 24, 1991 event involving the unanticipated
start of an emergency diesel generator was required to be
submitted on March 26, 1991, and was submitted on June 30, 1991.
4.
An LER for a November 13, 1990 discovery of non-qualified
.electrical splices on equipment inside containment was required to
be submitted on December 13, 1990, and was submitted on January
28, 1991.
-
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Consumers Power Company is hereby
required to submit a written statement or explanation to the U.S. Nuclear
Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555
with a copy to the Regional Administrator, Region III, and a copy to the NRC
Resident Inspector at the facility that is the subject of this Notice, within
9403010029 940222
ADOCK 05000255
G
30 days of the date of the letter transmitting this Notice of Violation
(Notice).
This reply should be ~learly marked as a "Reply to a Notice of
Violation" and should include for each \\ifolation:
(1) the reason for the
violation, or, if contested, the basis for disputing the violation, (2) the
corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the
date when full compliance will be achieved., If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for
Information may be issued to show cause why the license should not be
modified, suspend~d, or revoked, or why such other action as may be proper
should not be taken.
Where good cause is shown, consideration will be given
to extending the response ti~e.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response
shall be submitted under oath or affirmation.
Dated at Lisle, Illinois,
this ;;? day of {__&b, 1994
- U. S. NUCLEAR REGULATORY: COMMISSION*
Report No. 50-255/93032(DRP)
Docket No. 50-255
Licensee: Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
REG ION I I I
License No.
DP~-20
Facility Name:* Palisades Nuclear Generating Facility
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
December 17,
1993~ thro~gh January 28, 1994
Inspectors:
M. f. Parker '.
D. G. Passehl
Approved By:
W. Kropp, Chief
Dat'e
7 *
Reactor Projects Section 2A
- Inspection Summary
Inspection from December 17; 1993. through January 28, 1994
- .,
(Report No.
50~255/93032(DRP))
.
Areas* Inspected: .Routine, unannounced inspection by the resident inspect~~~
of actions on licensee event report followup, followup of events, operational.
saf~ty verification, maintenance, surveillance, engineering and design issues,
regional requests, and report review:
No Safety Issues Management. System*
(SIMS) items were reviewed.
- Results:* Of the eight areas inspected, no violations or deviations were
- identified in six areas.
One violation:was identified *for failure to take
effective corrective action (paragraph 2:b) and one unresolved item was *
identified concerning a vacuum drying procedure (paragraph 7.a).
A strength was noted for the licensee's implementation of a comprehensive and
conservative inspection prog~am for in~pecting fuel assemblies destined for
dry fuel storage. A weakness was noted for submittal of an LER beyond the 30
day reporting requirement of 10 CfR 50.73(a)(l).
Further review found other
LERs not reported within the required time frame.
An unresolved item was
identified for the possible lack of adequate verification of the level of
vacuum obtained during the vacuum drying process used for Ventilated Storage
Casks (VSCs) 1 and 2.
9403010035 940222
ADOCK 05000255
0
.
.
1.
DETAILS
Management Interview (71707)
The inspectors met with licensee representatives (denoted in paragraph
11) on January 28, 1994, and informally throughout the inspection
period, to ~ummarize the sctipe and findings of the inspection
activities.
The inspectors also discussed the likely informational
content of the inspection report, with regard to documents or processes
reviewed by the inspectors.
The licensee did not identify any such
documents or processes as proprietary.* .
Highlights discussed during the exit interview were:
a.
Strengths noted:
The li~ensee has implemented a co~prehensive and
conservative insp~cti9n program fo~ inspecting fuel
assemblies destined for dry fuel storage (paragraph 4).
b.
Weaknesses noted:
An adequate verification of the level of vacuum obtained
during the vacuum drying procass used for Ventilated Storage
Casks (VSCs) 1 and 2 may not be available.
An unresolved
item was identified (paragraph 7.a).
An LER was submitted .beyond the 30 day reporting requirement*
of 10 CFR 50.73(a)(l). Further review found other LERs not
reported within the required time frame
(~aragraph 2.b).
2. *
Licensee Event Report Followup (92700, 92720)
The inspectors reviewed the following Licensee Event Report (LER) by*
means of direct observation, discussions with licensee personnel*, and
review of records.
The review addressed compliance to reporting
requirements and, as applicable, whether immediate corrective action and
appropriate action to prevent recurrence had been accomplished.-
The LER
discussed an event when both emergency diesel generators (DG) were .
simultaneously inoperable.
This LER was submitted beyond the 30 day
reporting requirement of 10 CFR 50.73(a)(l).
The licensee's corrective
- actions to address the failure to submit a timely LER were considered a
separate issue.that is discussed in paragraph (b) below ..
a..
(Open) LER 255/93013:
Loss of Emergency Onsite AC Power Du~ To
Both Emergency Diesel Generators Being Simultaneously Declared
Inoperable:
On April 27, 1993, with the plant at 100 percent
power, DG 1-1 was test started and loaded to approxi~ately 500 kW
prior to removing DG 1-2 from service -to perform preventive
maintenance.
After approximately five minutes of operation, the
load on DG 1-1 dropped to zero and DG 1-1 was declared inoperable.
In accordance with the Technical Specifications, DG 1-2 was
started. and loaded to verify operability.
However, by paralleling DG 1-2 to the electrical distribution grid
to accept load, DG 1-2 was rendered inoperable. Specific types of
grid failures, occurring while a DG was paralleled to the grid,
- could cause the DG to trip on overcurrent and lock out.
The DG
would then be unavailable for automatic loading if the grid
failure should progress into a loss of offsite power.
Since the
specified function of the DG was to automatically start and load
upon loss of offsite power, the DG would.not be capable of
performing this specified function.
Therefore, the DG must be
declared inoperable whenever paralleled to the grid.
Since both DGs were simultaneously inoperable, Technical
Specification 3.0.3!
(~lant shutdown within one hour) was entered,
and an Unusual Event was declared in accordance with the emergency
operating procedures.
Correttive actions included submitting a rev1s1on to the
electrical section of the Technical Specifications to emulate
NUREG 1432, "Standard Technical Specificati~ns for CE Plants."
The proposed Standard Technical Specification provides enough time
to complete the test run of a DG and not declare both DGs
simultaneously inoperable.
The cause of the DG 1-1 failure was a defective fuel oil booster
pump.
A new pump was installed and satisfactorily tested.
Operating procedures were revised to more closely monitor the fuel
oil booster pump for degradation.
b.
Title 10 of the Code of Federal *Regulations, Part 50.73 (10 CFR
50.73 (a)(2)(i)(B)) requires that the licensee submit an LER
within* 30 days of the discovery of any operation or condition
prohibited by the plant's Technical Specifications. Therefor~. the
licensee was required to ~ubmit an LER within thirty days after
having both DGs inoperable on April 27, 1993.
The licensee did
not submit this LER until December 23, 1993, a period of 180 days.
Upon further review, the inspector noted the following previous
examples where the licensee failed to submit an LER within the
requ fred ti me:
(1)
LER 91-10 was submitted 80 days late for a February 24, 1991
unanticipated start of.an emergency diesel generator during
performance of a special test. This resulted in a violation
which was issued in Inspection Report No. 50-255/91012.
(2)
LER 91-02 was submitted 46 days late for a November 13, 1990
discovery of non-qualified electrical splices on equipment
inside containment, a condition outside the design basis of
the equipment.
This resulted in a violation which was
issued in Inspection Report No. 50-255/92004.
3
(3)
During the review of other potential late LER submittals,
the licensee di~covered another event similar to LER 93013,
involving simultaneous inoperability of both emergency
diesel generators in May 6, 1992 that should have been
reported. A licensee representative stated that the
licensee would report that event in a supplement to LER
93013.
.
Based on the above, the failure to report that both DGs were
simultaneously inoperable on April 27, 1993, with the plant at 100
percent power, represents a failure to take effective correction
action to preclude recurrence. This is considered a violation of
10CFR50, Appendix B, Criterion XVf (50-255/93032-0l(DRP)).
One violation was identified.
No deviation~, unresolved, or inspection
followup items were identified in this area.
3.
Followup of Events (93702)
During the inspection period, the licensee experienced two events, one
of which required prompt notification of the NRC pursuant.t6 10 CFR
50.72.
The inspectors verified that the notification was correct and
timely, that activities were conducted within regulatory requirements,
and that:corrective actions would prevent future recurre~ce. The events
are described below:
a.
On December 17, 1993, while attempting to restor~ the Cook -
.
b.
Palisades #1 345 kV circuit, Indiana & Michigan Power personnel' at
the D.C. Cook plant closed the Cook -.Palisades "Nl" automatic
circuit breaker (ACB}, with the three phas~ line grounds at
Palisades still attached.
The line grounds were in place to allow
performance of a preplanned outage for general maintenance on
transformers and associated motor operated airbreak switches at
Benton Harbor.
The Cook - Palisades #1 offsite power supply deenergized after the
ground was sensed.
However, as a result of a failed bre~ker relay
in the Palisades switchyard, both the Cook - Palisades #2 and the
Argenta - Palisades #2 sources supplying offsite power to
Palisades were lost. Thus, three of the six offsite power
- supplies to the site were rendered unavailable at the same t1me.
Following repair of the failed breaker relay, power was restored
to the three offsite power sources later the same day.
On January 21, 1994, both the "A" and "B" trains 6f control room
HVAC were declared inoperable due to ice and snow clogging the
emergency air intake plenum.
Technical Specification 3.0.3 was
entered and a prompt telephone notification to the NRC pursuant to
10 CFR 50.72 was made. The inoperable condition lasted about 12
minutes, until utility workers could brush away the snow .
At the time of the event, plant operators were performing M0-33,
4
"Control Room Ventilation Emergency Operation," Rev.3, when a
positive pressure of 0.125 inches wg (water gauge) pressure could
not be maintained in the control room due to the clogged intake
plenum.
After unclogging the plenum, control room pressure
returned to 0.0250 inches wg.
The licensee issued a deficiency
report and will address preventive actions during future
performances of this surveillance test.
No violations, deviations, unresolved, or inspection followup items were
identified in this area.
4.
Operational Safety Verification (71707, 71710, 42700)
Routine facility operating activities were observed in the plant and
from the main control room.
Plant startup, steady power operation,
plant shutdown, and system lineup and operation were observed.
The performance of reactor operators and senior reactor operators, shift
engineers, and auxiliary equipment operators was observed and evaluated.
Included in the review were procedure use and adherence, records and
logs, communications, shift turnover, and the degree of professionalism
of control room activities.
Evaluation, corrective action, and response for off normal conditions
were examined.
This included compliance to any reporting requirements.
Observations of the control room monitors, indicators, and recorders
were made to verify the operability of emergency systems, radiation
monitoring systems, and nuclear reactor protection systems.
Revi~ws of
surveillance, equipment condition, and tagout logs were conducted.
Proper return to service of selected compone~ts was verified.
- . Periodic verification of Engineered Safety Features status was conducted
by the inspectors.
Equipment alignment was verified against plant
procedures and drawings and detailed walkdowns selectively verified:
equipment labeling, the absence of leaks, housekeeping, calibration
dates, .operability of support systems, breaker and switch alignment, as
appropriate.
a.
General
The plant has been on line at essentially full power since the end
of the 1993 refueling outage. Activity levels of the primary
coolant system showed no significant adverse trends and were
closely monitored and reported daily. *
b.
Dry Fuel Storage Fuel Handling Inspections
The inspector observed selected portions of the licensee's fuel
inspection activities for the dry fuel storage project that
commenced on January 10, 1994.
The purpose of the inspections was
. to verify the identity and integrity of fuel assemblies destined
5
for dry fuel storage.
The inspections were performed visually and
ultrasonically.
The licensee_ intended to perform visual inspections (VT} and
ultrasonic inspections (UT} on 300 fuel assemblies.
In addition,
another 80 fuel assemblies that have already been visually
inspected were planned to have an.ultrasonic inspection.
The
inspections were scheduled to be performed over the next few
months.
A total of 264 fuel assemblies that satisfactdrily pass
the VT and UT testing were scheduled to be placed into dry fuel
storage in the current year.
The remaining fuel
ass~mblies that -
pass inspection were scheduled for a later date.
To date, visual examinations on 100 fuel assemblies had been
completed and no assemblies had been rejected. Several of the
assemblies had indications which will be evaluated and confirmed
by UT and dis~ositioned by engineering.
The inspector's review found that the licensee had implemented a
comprehensive and conservative inspection program for this
activity. Three licensed operators and three fuel inspectors had
been trained and dedicated to this task. There were daily pre-
and post-job briefings with the crew to identify any equipment
problems or other concerns.
The operators, fuel inspectors, their
supervisors, and the fuel handling system engineer wer~ all *
involved in the daily briefings.
-In addition, the licensee held an infrequent evolution pre_.,.job
briefing prior to start of the fuel inspections.
The brief was.
thorough, with good discussion between management and workers of
plans, procedures, safety precautions and ~anagement expectations.
- Expected radiological conditions were discussed and stop work *
points ~ere clearly identified.
No violations, deviations, unresolved, or inspection followup items were
identified in this area.
5.
Maintenance (62703, 42700)
Maintenance activities in the plant were routinely inspected, including
both corrective and preventive maintenance.
Mechanical, electrical, and
instrument and control group maintenance activities were included.
The inspection was to assure the maintenance activities reviewed were
conducted in accordance with approved procedures, regulatory guides and
industry codes or standards, and in conformance with Technical
Specifications.
The following items were considered during this revi~w:_
the Limiting Conditions for Operation were met while components or
systems were removed from service; ~pprovals were obtained prior to
initiating the work; activities were accomplished using approved
procedures; and post maintenance t~sting was performed as applicable.
6
\\
The following maintenance activities were observed:
-
a.
Repack of Service Water Pump P-7A
b.
Service Water Pump P-7A breaker inspection
c.
Boric Acid Leak Walkdowns
The inspector performed a walkdown with maintenance department
representatives of areas where there was evidence-of boric acid
leaks. During the walkdown, the licensee's boric- acid program and
the associated procedure, EM-26, "Boric Acid-Leak Inspection,"
- Rev.a, was discussed.
The purpose of the program was to perform
inspections of carbon steel components in all plant areas to
ensure no degradation exists due to boric *acid leakage:_--
Although some h6usekeeping concerns were identified, the-program
appeared to be effective.
Many areas showed overall improvement
since the end of the recent refueling outage when weaknesses
regardi~g the large amount of ~ontaminated areas and the excessive
use of catchments to dir~ct or contain boric acid leaks were
observed.
Th~ material condition of the east and west safeguards.
pump rooms had improved somewhat._
-
However, ther~ were ~till some wea~ areas sue~ as.removing the
boric acid buildup in catchments ~nd valve stem areas with boric
acid deposits. These obs~rvations were discussed.with the
maintenante personnel and plant management.
No violations, devia~ions, unresolved, or inspection followup items were
identified in this area.
-
.-
, .
. 6.
Surveillance (61726, 42700)
The inspector reviewed technical specifications required surveillance
testing as described below, and v~rified that testing was performed in
accordance with adequate procedures, test instrumentation was_
calibrated, and limiting conditions for operation were met.
The
inspector further verified that the removal and restoration of the
affected components were properly accomplished, test results conformed
with technical spe~ifications and procedure requirements,* test results
were reviewed by personnel other than the individual directing the test,
and deficiencies identified during the testing were properly reviewed
and resolved by appropriate management personnel.
a.
QE-35, "ED-01 and ED-02 Battery Checks - Quarterly," Rev. O
b.
Q0-14, "Inservice Test Procedute - Service Water Pumps," Rev.5
c.
RI-99, "Left Channel Nuclear Instrument Calibrations," Rev.2
d.
MI-2, "Reactor Protective Trip Units," Rev.37
7
._.
e.
. f.
M0-7, "Emergency Dies~l Generator 1-1 {K-6A)," Rev.29
Q0-30, "Engineered Safety Room Cooling and Ventilation-System,"*
Rev.a
No violations, deviation~, unresolved, or inspecti6n followup items were
identified in this area.
7.
Enqiheerinq and Design Issues (37700,92705)
The inspector monitored engineering and technical support activitjes at
th~ site including support from thJ corporate office. The purpose was *
to assess the adequacy of these functions in contribµting properly to
other functions such as operations, maintenance, testing, training, fire
protection, and configuration management.
a.
The inspector reviewed the licensee '.s calibration and procedure
controls for dry. fuel storage canisters after learning that
another nuclear utility may not have dried the canisters to the
vacuum pressure required by technical specifications. This review *
found that the plant specified tolerance for calibration of .the
Sensotec Digital *Gauge Pressure Instrument, used to measure the
level of vacuum in the dry fuel casks prior to helium backfill,.
~as plus or minus 0.25 percent of full scale (equal to. plus or
minus 0.063 psi a) ..
This toleran_ce was ]napprppriate s1nce the*
- . required pressure tolerance needed per procedure was less th~n
. 0.060 psi a.
The licensee issued a deviatio~ repoit 6n the inspectors
observation,and had preliminarily ~oncluded that adeq~ate *
- verification o_f the level *:of vacuum obtained during drying may not
'be-available._ However, the licensee's ,nalyses of existing
records showed no significant reduction in the effectiveness of
. the qry fuel* storage cask confinement system existed .. * According
- to FHS-M-32~ "loading and Placing-the Ventilated Storage Cask into
Storage," Rev.I, the measured pressure readings following vacuum
drying for both Ventila~ed Storage Casks (VSCs) was 0.00 psia.
Therefore, assuming worst case tolerance, the VSC pressure could
have been 0.003 psi a greater than the required value.
The licensee sent the pressure instrument to an offsite
calibration laboratory for a rigorous comparison of true versus
- indicated pressure measur~ments. Those results showed the
_
instrument to be more accurate than previously reported, to within
plus or minus 0.05 percent of full*scale, ~r plus or minus O.Of25
. psia.
However~ the inspector later learned that the pressure
instrument's digital readout was set to read 0.00 psia when
measuring any pressures below 0.10 psia. Therefore,* pressure in
the VSCs may have been as high as 0.1125 psia, almost twice as
high as required per procedure.
The licensee was reviewing
8
b.
additional logs and interviewing personnel to try to better
determine what level of vacuum was actually obtained.
Pending
further review by the licensee and NRC this matter 1s considered
an Unresolved Item
(50-255/93032-02 (DRP)).
The purpose of vacuum drying the VSCs was to evaporate any
moisture that could lead to degradation of the fuel cladding.
The
- licensee contacted the VSC designer, who stated that the small
amount of overpressure that may have existed would not result in a
significant reductiori in .the effectiveness of the dry fuel storage
cask confinement system.
The inspector's review found weaknesses in the vacuum drying
procedure that failed to address the operating features-of-the~--------
instrument at pressures below 0.10 psia. There were apparent
weaknesses in personnel not quest~oning the adequacy of the
procedure, nor in questioning the suitability of the instrument
for use at the lciw pressures.
Althoug~ the instrument was
supplied by the cask manufacturer, the licensee failed to
thoroughly check its operating characteristics.
NRC .Region III mariagement and the Materials and Processes S~ction,
Engineering Branch, Division of Reactor Safety have reviewed the
existing open items for the Palisades Nuclear Power.Plant and have
determined that the fol~owing open items will be closed
administratively due to safety significance relative to emerging
priority issues and to the age of the item. lhe licensee ~s
reminded that commitments directly relating to these open items
are the responsibility of the licensee and should be met as
committed.
NRC Region III.will review licensee actions by
periodically sampling administratively tlosed items.
(1)
(Closed) 50-255/89007~01 through 11
50-255/89024-02 through 05, 50-255/90023-01. and
50-255/90025-01 through 24
These items .mainly pertain to*
the adequacy of design controls for large bore piping.
Inspection report number 50-255/89007 found a variety of
small errors indicative of w~ak design controls during the
modification process.
At the time, there were iridications
that the original I.E. bulletin (IEB) 79-14 program and the
seismic design bases were not sound.
The. 1 i censee
acknowledged the design control weaknesses and implemented
changes to *the process.
Inspection report number 50-
255/89024 reviewed modifications associated with the snubber
reduction project. During this inspection, additional
design control weaknesses were noted through the continued
assumption that the 79-14 calculations were correct. It was
eventually coricluded that the 79-14 calculations were
unreliable, both from an "as-built" as well as a
calculational accuracy perspective.
The licensee again
acknowledged the problem and committed to do a sample
9
program to evaluate the significance of the discrepancies.
Inspection report number 50-255/90025 reviewed the
modifications associated with the steam generator project.
In this instance, design control problems were noted with
the consultant performing the piping analyses.
In addition,
it was noted that the seismic design bases had been changed
or were not being met by CPCo.
As a result of this last
inspection- a comprehensive program was implemented by the
licensee to reconcile the design bases problems and to
reanalyze all of the safety-related pi~ing.
All of the above violations or unresolved items fall under
design control, procedures, or corrective actions.
Most
-individual -issues were- resolved prior to the end of the*
inspections, and all responses to violations were reviewed
and found acceptable.
NRC will periodically inspect the
licensee,s ongoing "Safety Related Piping Reverification
Program."
(2)
(Closed)S0-255/89026-01 through -03:
NRR had granted
interim relief for these items and the licensee s~bsequently
performed acceptable tests, therefore, these items can be
closed.
(3)
(Closed)50-255/92013-0l through 04:
These items were
duplicates of items tracked as 50-255/92012, that were
closed in Inspection Report 50-255/93005; therefore, these
items can be administratively closed.
No violations, deviations, o~ unresolved items were identified in
this area.
One Unresolved Item was identified ..
8.
Regional Requests (92705)
a.
Concerns:
The inspector reviewed the following three concerns.
1.
Concern:
There was a common practice for maintenance
personnel tri change the description of maintenance work
performed and equipmerit/consummables used for the work.
The inspectors interviewed maintenance department repairmen
and supervisors. Additionally, Administrative procedure
5.01, "Processing Work Request~/Work Orders," Rev. 12, was
reviewed.
Result:
The inspectors were unable to substantiate this
concern. Although uncommon, the "Summary of Work Performed"
section of completed work orders was sometimes clarified or
enhanced by maintenance personnel prior to being typed into
the licensee's computerized work order system.
Work orders
were copied on microfilm and retained for the life of the
plant.
The original work order "hardcopies" were destroyed .
10
Parts for safety related applications were specified
initially front by the mai_ntenance planners. Specific parts
needed for an activity were identified by stock number,
description, etc. There were occasions when specific parts
could not be identified because the exact equipment problem
could not be determined unti.l disassembly and inspection.
In these instances, parts were identified for safety related
work after disassembly.
Controlled material~ used were required to be listed on
completed work ord~r documentation for "Q-listed" work.
Components required to function during accident conditions,
and pressure retaining components as defined by the ASME
B&PV code, were required to have appropriate documentation
of materials used;
2.
- Contern:
An employee was caught sleeping in the equipment
hatch area while assigned to hatch watch duty, on or about
November 19, 1989. The inspector interviewed the maintenance
supervisor who witnessed the employee sleeping.
No other
individuals were known to have witnessed. the employee
sleeping.
Result:
The inspector was unable to determine whether the
- employee was sleeping.
However, the employee appeared to be
inattentive to his duties.
The maintenance supervisor stated he observed the employee
to be motionless for a period of time, resting against the
equipment hatch bulkhead.
He was unsure if the employee was
sleeping because he could not see his eyes.
The employee
was wearing utility-supplied dark safety glasses.
The
safety glasses were used to bl o.ck the glare from the new
high intensity lights that were installed on the polar
crane.
The maintenance supervisor informed the employee's
direct supervisor of the conduct and took disciplinary
action.
'
The equipment hatch watch was established during outages to
quickly shut the equipment hatch upon orders from plant
operators.
No plant conditions existed that required
closing the equipment hatch during this time period.
The
equipment hatch watch also typically serves the dual role as
crane operator.
3.
Concern:
Mechanical repairmen were recently laying around
the radiological controlled area (RCA). The inspector
interviewed several radiological protection (RP) technicians
and two RP supervisors. Specific questions asked to these
individuals were:
(a)
Did they observe any individuals laying or loitering
11
around the RCA during the last refueling outage that
began in June 1993;
(b}
What action did they take if any such individuals were
identified while in the plant; and
(c}
What were management's expectations.
Result: This concern was substantiated in that there was a
common practice for workers to pre-stage in a low dose area
while waiting for a job, such as welders waiting to start
work.
On a few occasions workers were asked to relocate
from a low dose rate area to* a lower dose rate ~rea. None
of the individuals interviewed identified anyone sleeping~
In addition, the resident inspectors have not identified any
cases of individuals sleeping in the RCA.
All of the RP personnel stated that if individuals were
confronted and did not obey directions to relocate, the
outage manager would be informed or other members of senior
plant management.
Job s~pervisors were expected to ensure
good ALARA practices were maintained.
Ultimately, the
responsibility of good ALARA practices rests with each
individual, as taught during General Employee Training .
. There were documented instructions that prohibit loitering
in the RCA.
Attached to every radiological work permit was
a page from administrative procedure 7.03, "Radiation Work
Permit,~ Rev.12, describing individual responsibilities for
proper radiation safety. Administrative procedure 7.03
provided specific direction not to loiter in radiation or
airborne areas, and tti use low dose areas as practicable to
accomplish work.
b.
The inspector followed up a Region III request to verify the
. satisfactory condition of the Palisades main turbine/generator.
The request came in response to .a main low pressure turbine
failure that occurred on December 25, 1993, at the Detroit Edison
Fermi Plant.
The overall condition of the*Palisades main turbine/generator was
good based upon bearing vibration level, generator.core vibration
level, and hydrogen usage.
The Palisades main turbine/generator has nine bearings that are
continuously monitored by an offsite contractor (Bently Nevada
System}.
The system alarms at seven mils (alert level} and at
fourteen mils (danger level}. The alarms activate both at the*
Bently Nevada System location and in the Palisades' main control
room.
At the time, there were no bearings in the alarmed state.
Also, there were no discernible differences in vibration levels
12
over the past year.
- The Westinghouse "Gen-Aid" Sy~te~ continubusly monito~s ~ibration
of generator bearings seven through nine, as well as vibration on
the generator core. Direct communication between the Westinghouse
di~gnostic center and the main .control room would alert the
.
operators to any adverse trends.
No adverse vibration trends have
occurred in the past year.
Hydrogen usage was monitored daily by the plant operators.* No
significant increase in usage has been observed over the past
year, indicating steady generator hydrogen seal performance.
No violations, deviations, unresolved, or insp~~tion followup items were
identified in this area.
9.
- Unresolved Items
Unresolved items are matters about which more information is required.in
6rder to ascertain whether they are acceptable items, violations, or
deviations.
An unresolved item disclosed during the inspectio~ is
discussed in paragraph 7.a.
10.
Report Review (90713)
During the inspection period, the inspectors reviewed the licensee's-
monthly operating report for December, 1993.
The. inspectors confirmed,
that the i~formation'provided met the reporting requirements of TS 6.9.1.C a~d Regulatory Guide 1.16, "Reporting of Operating_ information."
No violations, deviations, unresolv~d, or inspecti~n followup items wer~*
identified in this area.
11.
Person~. Contacted
Consumers Power Company
- G. B. Slade, Plant General Manager
_
.*R. D. Orosz, Nuclear Engineering & Construction Manager
R. M. Rice, Director, NPAD
'D. D. Hice, Nuclear Training Manager
- T. J. Palmisano, Plant Operations Manager
D. W. Rogers, Safety & Licensing Director
- K. M. Haas, Radiological Services Manager
R. B. Kasper, Maintenance Manager
- K. E. Osborne, System Engineering Manager
C. R.
Ritt~ Administrative Manager
J. C. Griggs, Human Resource Director
- H. A. Heavin, Controller
J. L. Hanson, Operations Superintendent
13
D. J. Malone, Radiological Services Superintendent
J. H. Kuemin, Licensing Administrator
Nuclear Regulatory Commission CNRC)
M. E. Parker, Senior Resident Inspector
- D. G. Passehl, Resident Inspe~tor
- Denotes* those present at the exit meeting on Ja~uary 28, 1994.
In addition, the inspectors interviewed qther licensee personnel
including shift supervisors, control operators and engineering
personnel.
14