ML18059B114
| ML18059B114 | |
| Person / Time | |
|---|---|
| Site: | Palisades |
| Issue date: | 07/14/1994 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18059B112 | List: |
| References | |
| 50-255-94-08, 50-255-94-8, NUDOCS 9407260177 | |
| Download: ML18059B114 (19) | |
See also: IR 05000255/1994008
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. *.U.S. NUCLEAR REGULATORY COMMISSION
. * REGION. I II
Rep~rt No. *50...:255/94008(0.RP)
. Docket No*. * 50:..255 *
Licensee~ Consumers Power Company _
- 212. West ~ichigan*A~~nue.
- ** * Jackson, *MI
~9201 .
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License No$. DPR-20 .
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. ::*J* Faci_lH.Y _Nam~: : Pa:lisades Nucl~ar *Generating *Facility
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- : Jnspec~ion At:* ***:Palisades Site~< Coverf;*Michigan *
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- Insp_ectfon c:~nducted*: --M~y 10 *through June *30, 1994
- Irispect~rs: *W.
J~ Kropp
M. "E *. Parker.
D.: G. eassehl :
- ~ J .. H. Neisler
J. L. *Hansen ..
C. ~-I .Or.sT ""' * ..
. Approved By: _W_+1n_
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w. J.'l<ropp/thi_ef
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Reactor.Projects Section 2A
-Inspection Summ~r~
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Ihs.pection from May 10 through june 30~ 1994: Report No. 50-255/94008CDRPl
Areas Inspected:. Routine, unannounced. safety inspection by resident and .
- . _regional* inspect"ors of actions on previous inspection findings; operational
safety verification, NRC Restart .Team, engineered safety feature ~ystems~
onsite ev~nt follow-up, current material condition, hou_sekeeping and plant
cleanliness,_ radiol_ogital controls, safety assessment and quality. *
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.:verification~ maintenance, surveillance, engineering and technical~ support,*
dry. fuel. storage acti~ities,. and review 9f license~ reports.
- Results:. ~Within. the 13 areas insp~~t-ed, no *violation.s. or -deviations ~ere,
identified in 12 areas.* One violation *was ide.ntified in the *remaining area*
- (paragraph 6.a) .*. Two Unresolved. Items were identified that pertained -to
contain~ent closeout (paragra~h 3.f) -and* a ~oritrol: rod i~terlock surveillance
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- The following is a summary.of the'licensee's_performance during thi.s
- inspection. period:*
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- ~3R72*DOco177 940720 :-
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K 05000255
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Plant*Operations
As a res.ult of the. exten~ive a11Jount of time the plant was. shutdo\\t!n* and the .
. : , .... -concerns expressed by the' Diagnostic* Eva 1 uat ion. Team (OET) in .the area of
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operations,: the NRC assembled a r~start team to.assess.the readiness of the *.
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- operations department to restart the plant. Operators on several shifts were
- observed prior to and during p 1 ant startup. Over a 11 performance. was
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- -satiSfactory; sonie spedfi c .concerns included. the 1 ack of an effective *' :-: * *
' cont a i nnient closeout program and the i_nforma 1 review of p_l ant Che,ckli st_s,* ....
- * following ~hanges.
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Safety As~ess~ent/Oua~ity Verific~iion
A management advisory group, consisting of four senior nuclear executj,ves*,.
performed an independent assessment of *pa 1 i sades during. the week of June 20, .
1994. *. Management oversight *was . a 1 so . provided dud ng the p 1 ant startu*p -for * . *-. *
critical evolutions and throu~hQut powe~ escalation.
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Maintenance and Surveillance ..
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- The lice~se~'s perf~rmanc~ in this are* ~as ade~tiate: A ~urveillance test:in
_hot shutdown required withdrawing a control rod less than two inches. This is
considered an unresolved .item pendi11g*further *review by the NRC into whether
or not the withdrawal of a control rod {less than two inches) constitutes a
mod~ change. .
_Troubleshooting of High Pressure Safety Injection {HPSI) *pump P-66A was
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- observed after the pump-failed to meet minimum flow-requirements.
Althoug~no *
definitive-root cause was identified, the licensee thoroughly e~pl~red the' "
. 'p_ossible causes and instituted frequent testing to verify operabil_i~y. -No:: -
problem~ have been observed to date.
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" Engineering and Technical Support .
The licensee's performance in this area was_ less than*adequate. A-violation
~as issued involving the failure to.test the spent fuel pool crarie using the
corre~t interlock bypass keys.
Post-modification testing failed .to deteC:t*
- that -the.interlock bypass keys on. the* spent fue 1 *poo 1 crane con.tro r box were * *
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DETAILS . * .
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persons Contacted *
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. *Consumers Power Conipanv __ .
- . *R.- :A.* Fenech, Vice President, ~uclear Operations ..
- T.- J. Palmisano, Plant General Manager.
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- *J. W. Muffet, Nuclear*Engineeririg & C6nstruction Manager
- w ~ F. Peabody,
N.E~O' Manager ( Interi~) *. :.
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-*R. * D. Orosz, Dir*ector, NOD Servfoes
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- *R; M. Swanson, Director, NPAD
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. *D. *.D~. Hice, Nuclear Training.Manager ;, _*: .*
- S~ Y. Wawro; Acting Operations Manager* *. ** .*
-*b. W .. Rogers.; .Safety & Licensing Director -
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~*R~ B. Kas~er, Maintenance.Mana~er *
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c~ Miller, System Engineering Manager* . -.
X. M. Haas, Radiological ~ervices Manager. :
- . *C. R.* Ritt, .Administrative M~nager
- *J. C. Griggs, Human Resource Di rector
- H. A. Heavin, Controller
- M. *A. Savage; Corporate Communications. *
D~ G. Malone, Shift Operations Superintendent
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- D. J. Malorie~ Radiological Servi~es Sup~r~isor -* ;
- J .. H.
Kuemin~ Licensfog Administrator.
Nuclear *Regulatory Commission CNRC>
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W~,J. Kropp~ Re~ctor Projecis ~ecticin Chief
- M. E. Parker, Se'nior Resident Inspector *.
- D. G. Passehl, Resident Inspector
- J ... H. Neisler, Reactor Inspector*.
J.* L. Hansen, Reactor Examinerflnspector
C. N. Orsini , Reactor Engineer
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. *Denotes those attending the exit interv~ew conducted on June 30, 1994 ..
The inspectors .al so had _di scussiOns. with other licensee.employees, .
- . inch1ding members of the technical and engineering .staffs, reactor .and**
- auxiliary J>perators, shift engineers and el ectri cal , mechanical and
instrument maintenante personneli and contract sectirity personnel ..
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. *Action on. Prevjoys* Inspection Findings. (92701)
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CClosedf Inspection FollowUo Item **C255/91019-19CDRS):
The battery .
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_charger rating exceeded the de-rated ampacity of the charger input
.. -... :.and output cables under_certain conditions.
The inspector
r~viewed the results of the licensee's ampacity study. -The cables
- were instrumented in the trays with the _greatest amount .of ca.ble
where the highest temperatures were.expected to occur.
- Approximately full charger load was applied for nine hours until
_ _ cable tempera~ures reached equilibrium. Cable temperatures at
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f~11.*1 oad were well below the cable design tempera.tu~e of* 90° c. * *. *
Also, battery charger loads were well below the rated loads for
the chargers .. This i.tem is.closed~ _** * .*.
b. * * CClosedl *Inspection *Followup ItelTI l255/91019.;.23lDRSl .and.
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_ - f255/92015-02CDRP): *The EDSFI.team questioned the abilitj of the.
Emergency Diesel Gen~rator (EOG} room heatfng ventilation and:air
- conditioning (HVAC} system. to maintain room temperature below 104°:." **
F with* only one of two fans fed from cl ass IE power.
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inspector conf1rmed by review of completed 111odifiCation FC-*9-39 .and*.*.
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app_l i cable.* revised *el e~tri cal drawfrigS* that' the E.DG room *HVAC .had .. ~
. been modified so -that all four EOG room, fans were powered from* : . . ..
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Class IE sources.* This.item is-closed~..
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c. :, 'cclosed) Insoection ~Followup frem *c2ss191019-24coRS): Abfl ity of*
.- : eme~gency diesel g~nerator exhaust system*td functio~ after ~n ::
earthquake._ The EDSFl team .Questioned the 1 ack of a* documented _ *.
. anchoring design for .the exhaust system. incl udfrig the mufflers*
whose ~nchor bolts were found to be cut off .. The inspector .; :
reviewe.d licensee's* specificati.on change* SC-92-079 with stress**
package 07003, DG Exhaust Piping Support ModifiC:ation~ that . * .. *
. documents the piping, including muffler, -system stress analysis,_* ..
~nd seismic support ~esign .. _The inspector's* walkdowri of the
diesel exhau~t system confirmed that the.supports had been
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.installed according to drawings and thal; the mufflers' restraints ...
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- were h1 place. Th.is item. is* closed .. _ ... *
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No violations, deviations, .unresolved, <l'r inspeclion followup items *were *.:
identified in this area.
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. * 3 >.. Pl ant Operat inns (71707, _ 93702)
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The pl~nt was taken criti~al'. and synthronized to t~e *grid on _June 18,-
>1994, after an extensive forced ()utage that began on February 17,-1994.
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- Several significant issues ~ere identified ~uring the forced outage ~ith
most findings and issues raised during the Diagnostic Evaluation Team**
{DET) visits in March and April 1994.
DET and license identified issues *
that required resolution prior to_plant*restart were* properly addressed.
On June 20, 1994, the licensee commenced Dry F~el Storage activiti_es by .
loading spent fuel assemblies .into the multi-assembly .sealed basket
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. {MSB}~ The licensee_ currently anticipates loading 1l casks this year.**
- Two. casks were previously loaded in 1993.
Each cask can accommodate up
to 24 spent fuel assenibl ies'.
Dry Cask -lo~ding activities were. scheduled
. to be** accomp 1 i shed over the next five . months with completion schedu l et1 * * .
in _November: 1994. .. *
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Operational Safety Verification (71707).
The inspectors .verified that the facility.was being operated in
. conformance with the l.icense and regulatory requirements and that
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the. 1 icensee's* ma.nagemeni-*control sy~tem was ~ffecti've in ens~ring.
safe operation of the plant.
On a sa~pling basis, the inspectors * *
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ve~ified proper control room staffi~g ~nd coordination.of plant - ..
. act iv.it i es;** verified operator adherence with procedures and * * . _ * _ ... _
technical specifications; monitored control roprri indications for._**.-. _*.
abnormalities; verifjed t_hat electrical power~wasavailable;* and
- observed.the frequency of plant and control room visits by station
management. *The inspectors reviewed applicable logs and conducted
- discussions with control. room'operators throughout the inspection.
- period.
The inspectors observed a . number of contra l_ room shift
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'* turnovers. * The turnovers were. conducte.d ~ in a profess i ona 1 *manner
..and included log r_eviews, panel.walkdowns,"_discussions of:*
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- mainteriance Arid surveillance ~~tiviti~s in progress or planned,
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and associated_ Leo time*restraints, as applicable.
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. . The insped:ors made:th~ f~llow.irig .obse;~*ation~ .with regard'-_to.
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. Personne 1 on ~evera 1 shifts -were observed with~ no actual *or
perceivedschedule pressure identified. Pre-job briefings .
- and shift turnover meetings were adequate-.. .
. Several p 1 ant evo l u*t ions wer~ observed having adequate
.**supervisory oversight. -Shift supervisors were obse.rved not
to be overburdened* with coll a_tera l duties ..
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- .. Operator logs *were_. checked for severa 1 .crews on. sever.al
d,ays .. -One ~oncerri was identified with the completeness of ..
.-_auxiliary operator log sh_eets.
Several items were ~ircled
as being out of the s*peci.fied range but were not expl aine_d
or discussed in the "comments ... section as required by a N_OTE *
on the.individual 16g.sheets. * *
A condensat~ pump recirculation.valve (FV-0730) did not open
. during the conaensate pump start due to the air to the valve
' * beirlg se*cured. ** The condensate system valve lineup checklist
- had been completed, but this valv& h~d b~en lef~ off of the *
checklist_.*
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- ~onditions and took appropriate action ..
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NRC Restart Team
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A.s a result of th_e exte!lsive amount of. time the pla~t was .s~utdown
and the concerns expressed by the Diagnostic Evaluation Team {DH)
in _the area of plant operat_ions, 'the NRC assembled a restart team.*
T~e purpose of the team was:to assess the readiness of the
operations department to restart the plant and to directly .observe
~estart acti~itie~. The team made extensive observations of
op~rations activities for a two week period pri_or~ to bringfog the
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plant on:.. line~* This inc.luded overviewing activiti~s performed ..
around the clock.*. Specific activities observed included:
valve* *. *
1 i neup checks~ pl ant wa l kdowns, startup surveillances,. ma i ritenante
activities, eqLi_ipment protective tagging,. operability* and
. * reportability .determinations, shift briefings, shift turna*vers,
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- *pre~job briefings, rod.manipulations~ approach to critical, *
- _criticality,, turbine generator _synchronizati_on;.and power ... *
.*. ".¢scalation. *
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- .Specific weaknesses or* areas.of concern identified by the. DET thaf --
- were reviewed by _the team included the: foll ~wing: ... : *
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- ~ * * ** .. Poor' planning* and.- direction by *ap~rations:*departme.nt ;
. management . : *
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Poor C?nshift su~ervisor.Y ~versigt\\t .. * *
.. Low pe_rform~~ce ~xpettat i ans*.*
Repetitive protecii~e taggirig prob1e~s *
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e * *.Operations department poorly support~d 'by" licensing a*nd * * ..
engineerin~ *
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Weak self assessment . anc:t co.rrecti ve acti o:n *. *
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The inspectors generally_ found that the. licensee had-*taken a'ctio~*- * .. * -* ,,
. or initiate.d steps to address the. DET's concerns. *In the* area of~*_*-:*
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- operability determinations, the licensee had-implemented a.
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completely new pro.grain.
Extensiv.i:i'management *avers.ight was : . ** -.
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. prov_ided throughout the pl.ant startup. Specific areas of c*ancern * .. . * -
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. are addressed .in this inspection repo'rt. Qverall, the team*
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concluded that the licensee had a successful startu~.
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Engineered Safety Feat~re CESFl Systems {71707)
Durin~ the ins~ection peri~d, the inspector~ sele~ted accessible . * *
port i ans of several .ESF systems to verify status .. * _Consi de ration
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was given to .the plant mode, applicable Techniial Specifications,*
Limiting Condit-ions -for Operation requirements, :and -other
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. :applicable. requirements.*
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Various-observations, where ~pplicable, were made*ot hangers and
supports; housekeeping;* whether freeze protection, if required,*
- was installed and operational; valve positio~ and conditions; ..
potential ignition sources; major.component Jabel*in~, lubri~ation *
. cooling, *etc.; whether .instrumentation was properly installed. :and
functioning arid 'significant process parameter values were*
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. .. consistent with. expe'cted value~-;- whether instrumentation was
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. calibrated; whether necessary support system~* were ope rational;.
- and whether locally. and remotely indicated breaker an'd valve.**
positions_ agreed. - *
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During.the .inspection~ the_ accessible portions **~f. the _followin.g .
- ~ystems were wa 1 ked down:*
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-containment*
. : .. - 2) * * *. Low Pre~sure Sa*f ety 'Injection:, .Tr~ i ~-. f\\ and . B
3) : *.High Pre~sure safety Jrijection,'Trai_n A ilnd s:
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Auxiliary Feedwater,. Train A and B
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5 )_ . . Emergency *oi ese 1 Generator' Train A and . B
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The following itenis ~ere.identified d~ring the.walkdowns:.
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- several bearing cooling water va 1 ves (MV-FW140, MV:..FW142, *
MV:-:FW144, and MV_;FW146) .for auxiliary feedwater pump P--88
were not included on CL No. 12.5, "Auxil ia*ry Feedwater *
System Checklist (Except K-.8 Ste.am Supply)." The licensee*
confirme*d that these valves were co_vered under_ CL No *. 12.6,
"P~8B Steam S~pply Checkl1st." *
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- The inspector identified ~that t~e :chemical addition .tank*
- . T-35 to auxiliary feedwater pump P-8C discharge va 1 ve _ MV-
. FW249 should have been closed pet CL 12. 5 but was open .. *
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This deviation was approved by the shift* supervisor because
this valve needs to be open to add chemicals during start-
up.
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.The~e was ,a toncern regarding the :review of changes io ~he
plant ~hecklists;' The licensee ~equires the Plant Review
Committee to review all procedure changes,_--.but not ~hanges
made to-checklists .. *It appears that the thecklists, ~hich
. are an integral part of procedures, are not. subject to" the
- same contra 1 s as. procedures. * The 1 i censee has -agreed to
- eva 1 uate this concern.
Ons.tte Event Follow:..yp (937oi> .
During the -inspection period,_ the l i celisee experienced se\\lera 1 : .
. . events, SOllJe of wnich.r"equired prompt notificatio_n of the NRC
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pursuant* to 10 CFR 50.72w. The inspectors pursued the events
onsite with license~- and/or other NRC officials.* In each:case,
the inspectors verified that any required notification ~a~ correct
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and timely .. The i*~spectors also *v~rif.i.ed that the lic~nsee
initiated prompt and appropriate actions. ~ .. The* spesific eve_nts,.
were as follows:
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On May 23; 1994, while performing~ specia1.*test_on the* ** ..
- service water system,* the as-found flows *to the . .two control *
room heating, ventilation; and. ai.r conditioning* (~VAC} * *
coolers was less than the* minimum required flow. * Th~
- coolers* were designed to* provide cooling to control room *
- equipment and personnel during accident conditions~ ~*The. ,
_plant accident analyses requir~d 46-gallons pe~ minute. at . . ....
81. 5 degrees r. *to eaeh coo] er. . : . : '
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the measured flow for the two coolers'wa~ 45 gallons per *
minute. and 44 gallons per nii nute ... A J l *.other. fl ow * ._;.
requirements f()r the service water. system were .measl,l_red **
satisfactorily: Upon disassembly of:-the condenser, the * * * *
licensee .dis~overed that gas~et m~terial used to channel *.
- flow through the six-pass condenser had blocked some ~f the .
inlet *and outlet fl owpaths 1 n the conden.ser. .Pl ant workers .
removed the gaskets from both end bells of the condenser and.
installed new.gaskets and retested the system.
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water flows through the coolers increased appr6ximately 35
percerit, exceeding minimum design requirements .. The *
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assessed during* the review of t~e associated Licensee Ev.ent ....... : -. .
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on* May 30,- 1994; the licensee identified a* potential ~::.
containment sump blockage caused from.signs,:adhesive.
labels, and tap~. The inspectors will assess the ljcensee's
correcttve action during the review of Licensee Event Report* 94-014.
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- Curr.ent Material Con.dition (71707}
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.. The inspectors performed g~nera l pl ant as well.* as selected system
and component wa l kdowns. to assess the genera 1 and speci ft c
material condition of the plant, to veri.fy that work requests had*
. been initiat~d for identified equipment problenis, and to evaluate ...
housekeeping. * Walkdowns included an assessment of the buildings,*
components, and systems for proper: i dent if i cation and tagging,
accessibility, fire and security door integrity; sca_ffolding, .
.. radiological controls,*and any unusual conditions.~ Un~sual.
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- .conditions included but were* not limited to.water, oil, or.other:
- 'liquid~ on the floor or equipment; i~dications of leakage through
- ceiling; walls, or floors; loose insulation; corrosion; .excessive
.. noise; unusual temperatures; and abnormal ventilation and .. * * ..
. lighting.
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Soine minor material condition deficiencies:were identified by the
inspectors during plant to~rs:
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A*funn~l and bose routed to *a floor drain from l~i d~esel
- ~enerator jacket and lube oil.cooler ser~ice wat~r outlet
valves MV-SW-677 and MV-SW-676 had no work request_ tag and
did not appear* to be leaking. _..
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The inspector identified that pressurizer wide range*
pressure indicator PI"'.".1050 was ou_t of* calibration. _ **
- 3) * *.Several light b.ulbs for valve position *1ndication*on.the hot
shutdown panel w~re burned out. *
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. 4) ... Several oil bubblers. were dri.ppi_ng*o*if and. other oil _leak.s
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- . existed on equipment in the safeguards .equipment rooms *. . : .. ..
. * Many of these 1 ea ks were rfot *identified with def i Ci ency
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. S~rvice *water' l~aks *6n containment air coolers VHX~2 and . *- ..
.. *VHX:...3 were identified during a containment_ c 1 oseout tour. . . *:
In respons~ to the above items, the lic~n~ee evaluated th~.:
conditions and took appropriate,.action._ '
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_ House~eepinq and Plant Cleanlineis (7170i)
The inspectors monito,red the status of housekeeping an.d plant
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cleanliness for fire protection and.protection of safety-re]ated ._-.:
equi~ment from fntrusion of foreign matt~r. The i~spe~tcirs *
. identified the .. fo 11 owing conc~rtis ~ .
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~The inspecto~ ~n~ an 6perations'd~partrilent super~isor
- identified several housekeeping and platit.cleanljtiess*
deficiencies in containment during a ~l-0seout tour on -
- June 5, 1994.
The deficiencies.were.of concern as ... * *
mechanical*maintenance and ra~iation protection personnel
' had just informed operations* department personnel that the* -
containment was ready for c 1 oseo.ut inspection.
. *
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Among the items found in *containment were bags of tools~ ...
ladde,rs; .flashlights, plastic bags, .attachments for*var:ious *
hand power tools, and pieces of debris scattered about on
"different cotitairiment:~levations~.
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Further diScussions found that. *sorile. 'of t_he tools were staged .
for motor-operated *valve *testing . that was to be performed ..
- with the unit.in Hot Shutd6wn.
This ~as *n apparent
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miscommunication,_since the operations.supervisorbelieved ..
- this-equipment would be removed from containment until _ .
. testing was se~ to star~.
The inspector found the 1 icensee' s pr6g.ram for performing -
containment closeout was not fully effecti-ve .. Although the
. licensee's checklist 1.3, "250# Heatup Checklist Containment
- Building," Rev.24, required removal of transient equipment
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and*other loose material from containment pri6r.to Plaht-:.
- ~tartu~, there was no mechanism, ~ther than verbal.
,notification to *a~erations department, that ~ther .pl~nt
_departments had the areas clean and. ready for conta~nment. *: .
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closeout inspection.
The inspectors were concer_ned ~i th* the . - ...
lack of coordin.ation between station departments during_ the*
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. containment close*out.
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This matter is considered ari u*~resolved Item pending further_** .
review by the .licensee and .the NRC (50-,255/94008-0l(DRP. * ... * .To facilitate timely resolutio~ of thii item, the licensee:** * has agreed to* respond in w_riting within 60 days to descrjbe .* **
- . * what actions are* planned to ensu.re future con ta i nll'!!:!nt . *
, ... = .. - . closeouts w.i ll be ef feet i ve. .. . . . . . .. . . ... "
- 2)
. The *c1e*anli'ness of.-the ~'West",safeguards- rooni w_as no.t :' ' . . .. tommensurate with the. rest of.the.auxiliary building, -:.<'. . . . especially in the area of the Shutdown Cooling heat. : '.. . ..
- exchangers. :some ~xamples were ladders not ~ec~red properly**
- and personnel protective clothing being on the . fl oar . and not * * *
in the proper $torage bag.
, g.. Radiological control-s. (71707) -... . The inspectors verified.lhai pers~nriel were following health -~ .'physics procedures for.dosimetry, protective cloth.ing,. frisking,.* .. posting, etc.,_ and r~ndoml_y examined radi.ation prote~tion ~ " - * *
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instrumentation for use, operability, and calibratio_n. . ' One unresolved item was iden-tifled.: No v*ialations, deviations, or *
- in~pection followup items were identified in this area.*
4. Safety Assessment/Oyality Verification (40500and 92700) The i nspect'or noted. that a management advisory group,_ .cons 1st ing of four senior nuclear executive$, was*scheduled to perform an independent outside assessment of Palisades' performance progress du.rfog the._wee.k of".* . * *
- June 20, 1994.
- *
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Through dtrect observations;*discussions with licensee personnel, and review pf records, the fo 11 owing Licensee Event Reports ( LER) were . reviewed to determine that reportability requirements were fulfilled, that immediate corrective.action was accomplished, and that corrective action to prevel"!t recurrence had been or would be accomplished .in** accordance wi~h Technical_ Specific~tions (TS): . . ctJosedl LER 255/94001: f~il~re to maintain minimum pressure in the_** . . * 'Contra l . room with the HVAC- system in the emergency mode because 'the . .
- intake plenum was plugged with. ice _and snow.
On January 21, 1994, while
- the plant was at 100 ~ercent power, operations department personnel were
performing monthly surveillance test M0-_33, "Control Room Ventilati_on . :Emergency Operation," Rev.3, on the "B" train and observed that control* 10
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.. * . room pressut~ had dropped to 0.07 inc~es water'~~uge.{WG) pressure~** The procedure .requires that* control room* pressure be greater. than or equal to 0.125 WG. The licensee attempted to place- bo.th "A and B!'_ * ._. trains of .control room heating, ventilation,_ and air toliditioning {CR * HVAC) systems in the emergency mode .and was unable *to maint~in the 0.125 WG pressure. T.he licensee dee] ared both trains. of* CR HVAC. inoperable. * * . . . and entered Technical Specification 3.0.3. '.... .. . . -.. . . . . _,. . . . . ,*.
- *Subsequent i nvesi i gat ion found that . the :common i ntak~ :*pi en um was clogged . *.
with ice and snow~ Plant workers removed the ica and:snb~ from the .. ~ ~. *
- plenum intake screen :and control room pressure was*.restored .withiri *a few
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.minutes and the licensee exited Technical Specification 3.0.3.* *.*
- . *
~ - . - . . . . . . rtie.*"1.nspect~r found *ihe lic.ensee: t..ook ap'p*ropriate J>'reventive. actions.*.
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- , Those ac.tiOns*included changing .M0-33 to rec*ord control.room pressure**
- ... from. once per ten .hours to once per hour .. ~ 'in* addjtfon,. the. Mce:nsee . * , changed the al arm response* procedure* to instruct operators to *inspect.-.*
- the plen~m int~ke for blockage.if control room pressure' is lo~. *Thi~ *
item is closed. . . . ". * .
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.. ... * . . '*: . CCJOsedl' LER 255/92029: Inadverte~t. act i vat iori of left channel" sequencer caused by _operator* error. On April 4, \\992, an oper-ator opened the output breaker of Diesel Generator (DG) 1-1 *without. first paralleling
- the alternate power supp*ly to* bus
11lC 11 .as required by Standard Operating Procedure 22, Section 7~5.4. 1his resulted in d~-energization*of bus .. 11lC, II re~closing of the DG 1-1 ou_tput b~E!aker, .and activation of the>*
- [eft Channel Norma*l Shutdown Sequencer.-
The- lic~nsee's correcti.ve .. * . *
- actions for this incident wer~ to discuss tbe importance of procedural .~.
~ compliance with. all shifts and t.o discipline the operator wh.o made the** . * * ** * error.
- *
.. This incident was *one of. five examples included in*a viol at.ion iS$Ued in"* _ *Inspection Report* No: 50-255/92015 *for failure to follow procedures.
- . The generic . issue of :procedure compliance at Pa 1 i sades is a*ddressed in
the licensee's response to this ~iolation. :This item is closed~.
- *
CClosedl LER 2S5/92020: SIS* check valv*e leakage PCVs were not closed by
- each SIS channel as. assumed ln ~nalyses. On Ma~ch 3, 1992~ the l~censee
- . discovered .that four -safety injeetion header pressure control val yes .
. (PCVs), wf\\ich should have each .been closed by each safety injection* . . .. signal (SIS) channel, were arranged with ,two close~ by one SIS_ channel * and two closed by the .other. The four PCVs are *required to. ~lose on* an
- *_SIS to prevent diversion of high pressure ~afety injection.* (HPSI)._ flow .
. : Tbis condi~ion had'be~n previously ideritifi~d i~:1988. *Howeve~~:i~e resolution was to.use the.normal PCV pressure.controllers to assure valve closure rather than to modify* the $IS circuitry. These pressure contro 11 ers were non~saf ety /non-en vi ronnienta 11 y qu*a 1 if i ed, and therefore . cannot be relied upon to ~nsure that th~*PCVs re~ain closed.
.. ** . . . ' . - . . In April 1992 the PCV.control circuits .were modified such that both SIS channels provided a close signal to each PCV. This item is closed~ 11
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. *.. . ~ . **.* No vfolations, *deviations, unresolved*, or inspect~on followu'p items were .. identified in this area.-*. - . . s .. *:Maintenarice/Surve_i*llance. (S2703 & 61726) . -... ' .
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-::-* a. * Maintenance Activities (~2703}. *. . *. , . -~ Routinelyi station mainte~ance activiti~s ~er~ observed and/o~. * revi~wed to ascertain that they wer~ conducted- in accordance wi-th * ;. ~ *
- .approved procedures*, reguJ atory guides and i11dustry codes or
. *. * * . . standards,_ and i!l conformance wit~ technical *specifications. "
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- ' ,. . The following .items were: also *cons.idered .*dlJrfng -this. rev1ew*: .*
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. ":.: l imitin'g. conditions for. operation were met ~hi le' components or: . :- . . . systems were removed from service*; approv.als were .obtained_~pr1or .
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to initiating the work; functional testing *and/or calibrations .. . were performed prior to returning *components or systems. t_o: .. . *. . service; quality control *'records were maintained; and activities.*: .. *. wer:e accomp l i she_d by qualified personnel . * .
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Port ions of the fo 11 owi n9 maintenance act.i vi ti es ~ere observed and rev.f ewed: * _ "
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-'i. J .. ! 1}' * Work Order. 24303995: * Perform yearly inspedion of spent .* fuel pool c_ran~:* . * . .. ~.- . ; . . . - : '... -: . .--*;* ' . . 2) * Work* Order 24410673: Perform miscellaneous mechanic.al *work.*. . ,. ...
- * as directed by Consumers-*Power Company. * This .work *.order was*"
. :* ** .. -* -the control ling docunient used 'to document various dry fuel ' .. * .. storage project preoperational activities *(see P.aragraph a**. '" . of th.is report) ~
- *
.* Surveillance Activitiei {61726) .
- ~During *the inspection period,* the inspectors obse*rved tech~ical
specification required surv'eillance test.ing'and v.erified that. . .. . " .* .. I " .. ; i . ,. '! - I
- testing was performed in accordance with adequate procedures, that
test instrumentation was calibr~ted, that results confrir~ed*with: technical specification~ and procedure requirem~nts and*~ere * reviewed, and that any defici.encies ident.i.f.ied during the testing .. ** -c .
- .. :
were properly resolved. *.
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.. . . . . . ~h~ i~s~ecto~s also witnesse~ or reviewed.portion~ of :the* fo 11 ~wing surveil 1 ances: * 00-6. "Co 1 d Shutdown Va 1 ve Test Procedyre Clncl ud*i nq Containment Isolation Valves>~" Rev.23 t ._. .* - 2) * ... * QO-i9* .. *rnservice Test Procedure "". HPSI "p~mp and 'E:ss Check' }alve Operability Test.* Rev.11
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- The.inspector observed the.licensee's troubleshooting when
High Pressure Safety Injection {HPSI) pump P-66A failed to
- meet minimum flow requirements dufing testing.
The minimum * flow required ~as 30 gpm through the discharge orific~.-* The. flow rate during the test was approximately 12 gpm. The licensee ct'rained .-the fluid from the p~mp di sch'arge* to the orifice, *replaced the orifice, and retested the pump. The inspector- noted t_he . fo 11 owing: .. Step. 5.3.6;e instru_cted -the *op~rat.Qr to.record pump discharge temperature "~.~~n the pump-casing at the
- . location identified b.Y T or as identified by the'
.
- _*_ .. system engineer.".-*Neither of the two a*uxiliary
.
operators. knew what the "T" *meant~. indicating this**_ ~tep needed clarification .. The operators did:recei~e . instruction froin the system eng_ineer.* ' . .
. . . ' . . . . . . .. Step. 2 .. 4 of "Attachment -2 instructed th.e operator to . 'lightly tap miniflow check valve CK-ES3340 .. Tha*
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operators obtained a piping .and* instrument diagram to .* identify the valve. since -the valve was not l_abel_led. * Although the lack of proper labelling was a problem,
- . operafors *took** the proper action..
. . . . _.After replacing._the orifice, the licensee ran three tests* ..
- - and each had satisfactory re$Ult$ indicating the orifice w*as
. :*-_probably blocked. 'However, the licensee found no evidence . __ * of blockage of .the ori gi na l orifice. : The* licensee remqved* and ex*amined .the original orifice,' *and used a boroscope*to* inspect- accessible piping upstream and downstream from the*
- *remqved orifi~e and found no ~lockag~ or debris.
In order to assure adequate minimum flow, _the license~ -* .. performed additional daily testing of the pump *for *one week* and found nQ other significant performance pr_ob l ems..
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- During the performance of RI-47~. 'step 5.'12.4~ the. reactor .. operator was required to verify that a control rod could be** withdrawn while in *the manual individual *rod drive control * system mode. _At this time the operator-withdrew a si_ngle control rod less than 2inches to verify'that the control . rods could be withdrawn," .and then subsequently*il)serted the *.*. control rod back to "its.original position of fully inserted ... * . . . . ' . . . . " - ~ . . . . ,, Technical Specifications 1.0, Defin.itions, Hot Standby,** *
- .states:
"The reactor is cQnsidered to.be in a hot standby . condition** if. the average temperature of the prim(lry coolant (T.v.) is greater* than 525°F and . any* of the contra l rods. are*. -
- * .. withdrawn and the neutron flux power r.ange i n~trumentat ion .
. 'indicates less than 2% Qf rated power~ n . . . . ' .. .
- ~ .. *The inspectors had the fo 11 owing c.oncerns: ~<
' * ' . . Neither the SS or th'e CRS were aware that the . operator
- . * wfthdrew a control rod or that the pr~cedure, RI~47,
'. - r_equ ired a part i a 1 wi thdrawa 1 ** of a cont ro 1 rod to . verify no rod withdrawal prohibit (interlock) ex.hted.
- When the surveillance was authorized; neiiher th~ SS**
. or CRS were aware that at. the .cone 1 us ion of the J & .C * . surveillance the operator would be directed to ... ' * withdraw a control rod. lhe CRS was not ale~ted to .* the .required con~rol rod -movement when he .. authorized . performance .of RI-41, ~i Sections l~~ though 4.'0.did * not ac~howledge that a contrril rod ~ithdrawal_ or a *. mode change would be 'required. . . ' . . . . ' .
- The reactor operator did not notify the SS or* CRS when
he performed_ Step 5.12.4- of Rl-47 by withdrawing the
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co.ntro 1 rod. ' In -reviewing plant conditions durfog t"he performance of this ' evolution, the inspectors noted that the high pressure *
safety injection pump, P~6A, was declared inoperable, due to .. *its inability to provide minimum flow through the . . recirculation line. Technical Specifications 3.0.4. ~tates that: "Entry into. a reactor _operating condition or ct.her specified condition shall ~ot be.made when the conditions for the Limiting Conditions for:operation are not met and
- the associated action* requires a shutdown if ~hey are not.*
met within a specified time interval." .lhus, plant
conditions were not appropriate under'the circumstances to go from Hot Shutdown to Hot Standby condit~ons. .
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ln addition, the inspectors noted* the following factors that** . ~ontributed to the concern: *
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. Most notabl.Y, the failure of the reactOr operator to
- notify the sen tor reactor operator *of. the* cont ro 1 rod
. movement. :
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The lack of procedural guidance i°hat c.learly . .
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recognized the mode change or .controi.*rod withdrawal.
- * .. The failure to conduct a* prejob briefing to discuss
. * *.the requ i r~d procedtffe steps. *. *
Subsequent t~ the event /the l iCensee 'has* had .. extens"iv~ internal dial~gue to clearly define what ton~titutes control .* .
- rod withdrawal and to provide 'a basis for those assumptions ..... ~
Pendi~g revjew* by the NRC o(.the Hcensee's position. of what: * defines a rod withdraw,* the withdrawal of a control rod ... * *
- .* (les*s *than two inches). on Jun~ 12,° 1994; .is *considered. an* .. *
- unresolved ._Item ."(so . ..:2ss/94008-02(D~P)) ~ *
-
- .*One *unres~lVed item was ide.ntified. * No violattons, d*eviations, or*
inspection followup items were identified in thiS .area. . . . . . . . 6.. .* Jnqineerfng and Technical Sui>port (37700) a. * ** Spent* *Fuel* Pao 1 Crane Unexpectedly Stopped D~rirlg * Preoperat i otia 1 * .. Testing For Th~ Dry Fuel Storage Proj~ct ..
. * . * .. , .. o~. May 23, * 1994~ th*e i icensee i ifteci t.he Multi-Assembly Trans.fer < *.
- ** * * Cask (MTC) and the Multi~Assembly SeaJed Basket (MSB) out of the~
.cask washdown pit*with .the spent fuel.pool crane *cL~3) and . * * * .attempted to.mov~ the l~ad to it~ designated location in the SFP.': . During the 1 ift, L-3 unexpectedly stopped near the edge of the
- SFP:
The licensee returned.the load to the task ~ashdown ~it ~nd
- , commenced an investigation. The 1 i censee' s i nvest.i gat ion *
determined that the pro_blem was caused by operation of the two interlock override keys, designated as .Key Number 20.*and Key .. Number *21 an* .the L-3 control .. *box. The override keys allow certain. crane interlocks to be bypassed.so* that the crane can be. moved over the SFP. . . .
- The i rispectors revi e*wed this event and. d~termi ned that. the safety .
- .:significance was minor .. However, the.inspectors identified * . *
.* several problems associated with inadequate post-modification *
- ~- testing procedures, poor .. work: practices,* and lack of appropriate
- ' * . management i nvo 1 vement. * *
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' - - ._*The oper~tion of L-3 interlocks .. was*:designed.a~ folltiws:* ,, . -..
- .~.:- * e :* * : When operated, .Key 20* *allows the main hook on L-3 to travel
.-. , *only over the cask foading area in the north end of the SFP. \\. '; . 15 ... _ .. " : -* ... *-..-..-........ -.... ~* .. '
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. ) When operated, Key 21 a 11 ows no mov-ement of the main hook-- over any*part*of the SFP .. - When operated~ Keys 20. *and* 21 al lOw the.: main hook ori L-3 to . traverse th.e entire SF_P, includi.ng the ca$k .l.~adjng_area .. -- * The* licensee's *investigation found that the two override k~Y~* were electrically reversed~ such that Key 20. functioned. as Key 2f:a.nd *.*. ' vi~e-versa. Thus when the licensee attempted to move the m~in' .. hook on L-3 to the cask laydown area **with Key 20, the crane _* **.stopped.
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- __ The i nspe¢tors :determfoed that the. fun.ct i.oris of Key 20 *:and* 21. were*~ * ": * .
- . electrtcally reversed during an unapproved modific~tion_th~t
-involved rewiring of the L-3 control box in 1986. At that-time,
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. :* .the _l icerisee replaced the 1'."'3 control. box with an updat~d analog
- * . "~on_trol Chief" transmitter/receiver.* Plant personnel involVed-
- with -testing the new transmitter/receiver found the two overricje *:
. . :*keys *were electrically reversed .as-received froin the" vendor~. ._ .
- . -: Pl ant personnel resolved the prob l eni by reversing . the wiring i l'I * *
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the L-3 control box. Althoug~- the keys operated properly after *
- the r~ver~al, no documentation was generated to record the change.
'No design change was 1mplemented arid no drawings were_. updatecj_ ..... Furthermore, had a design change been implemented, plant personnel ** .- ** * _would have.likely changed the panel wiring on the crane rather ... ,. *" than* in the control box.- Correcting the panel wiring would h"ave
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been the preferred method of repair sinc"e the .spare. control boxe's .* would not nee~ to be reconfigured .. * *
.*
- The undocumented wirin~ chan~e in i986 remained :in pl~c~ tintil the
recent modification_ of L-3 performed in 1994 under.Specifi.C:ation- Change (SC) 93-094. Part of SC-93~094 called for updating the. * * analog L-3 control bo~ to a ~ew digital model. Wheri the new
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- control boxes wer~ ordered .under SC 93-094, the vendor configured
the control box identical to the earlier analog design. * * ... ~ Consequently, the keys on the new control boxes operated i.n the. incorrect fashion.
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. . The in~pe~tor reviewed the licensee's investigation ~nd.jdentified *
- -the following root causes:
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- The pl ant modi fi cation process *was not used." to_ document. the
wirin~ ~hanges made to the control box in 1986. Hence,.no do.cu_mentat ion existed to reflect the change in the plant drawings or the vendor files .. Further, th~ modi.fication *
- *process~ would likely _have identified the p~eferred method ,-of
repair beirig changes to the panel wirjrig* versus changes to the c~ntrol box wiring._
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The:~rocedure for testing the ~rarie following the rec~nt . modification in 1994 was inadequate since there were no * 16
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..... ' . *,. instructions to test or.verify proper opera.t1on. of the SFP interlocks.
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Work* instruction * WI-sc..:.93-094-01, "Sp.ent Fue*{ Pool Crane .Control Chief Modification," Rev.3, Step 8.4 .required . electrical maintenance personnel.to satisfactorily. perform* an operational check of the* crane. via a separate work **.
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instruction, WI-MSE.:.E-07, "Overhead Crane.Electrical -- *. * . Inspection," Rev.O .. However; WI-MSE-E-07 did not have ... explicit instructions to test .. the SFi> an.d. task l ~ydown areji ..
- interlock bypass*keys.: .. The only requirement was to verify__
that "contro.l station*switches" at Step 5.1.2, and "crane .. *.
- limit switches" .at StepS~l.3, operat¢dproperly .. The
.. instructions were a bare outline of what. was required~ with . no detaill or acceptance criteria to gui~e*maintenante '*
. personnel through the' various .. checks. that needed *to be :' . performed. . . . *
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. Although they checked that both .. keys al.lowed .the. main *hook*.
- on L-3 to ,traverse the entire SFP, the crew that performed
the post-modification testing on May 6, 1994, onli
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arbitrarily checked one of the.keys for the north end of the
- SFP.
When one key did not a 11 ow movement of the ma lf'.l hook . , over th~ north end of the SFP, they tried the other,* without . *noting -which ke.Y they had used to allow the interlock to be ..
- bypassed.
Th.ey *failed to verify that Key .Number 20 *operated.
- as inte.nded, and that Key*Nu111ber .. 21 operated a_s intended.' *
. : The inspectors. found* over.s i gilt . by. maintenance' and : . : << . erigi neer.i ng supervisors was -1 acki ng .. No supervisors w_ere present to observe the testing during the May 6, 1994, 'post- modification testing o~.L~3 crane.
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- The ~nspectors determined that th~ licensee rem~i~ed t~ compliance. : * * *
with the Tech~ical Spe~ifications (TS) during this e~ent. The * *. *: . applicable TS,* 3.2Lt.d, required that .heavy loads shall not be *" . * *
- ... moved over the 649 foot elevatio.n of the _auxili~ry building (SFP .. * .. *
- floor) unless no fuel h.andlfog**operations were in progress and, .
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Th.e L-3 interlocks* were* operable or . . . . ~ . '* ., . :** The L-3 interfocks were .bypass*ed and un~er the.* administrative control of a supervisor. . ..
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. . '* . . *- In this instanc*e~ no fuel handl.,ing was in :progre.ss .. 0 The L:..3* .
- interlocks were. effectively bypassed with the fund ions* on the L'.73 .
. . . control* box reversed *. A *heavy load*s supervi.sor was. present and .in cont~ol during the. entire evolution.
- Safet~ ~ignificancewas.minor since .at no ti~e was a h~avy loa~
moved over or. in danger of moving over fuel. sto_red in the SFP. .17
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- * .* All other prerequisites of c~ane operation had beeri ~u~filled- '
... prior to beginning the evol~tfon.. .
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. *. , -The failure to thoroughly test the L-3 crane during a 1994 . * .. ~odificatiori,* including the control box override keys, to assure .*. the. interlock/override. keys functioned. as designed,. is considered' .- - . . .. a violation of 10 CFR 50 Appendix B, Criterion XI, Test Control ,. (5.0-255/94008-03(DRP)):
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. _-- - . . . The licensee inip l emented appropriate corrective ~ct ions. as warrarite.d by this event:* The corrective actH>ns* included:* ... . . . . - . . . '- .. - 4t .* " C~rrect i ng the wi ~i ng prob le~ .*with .the keys . . . , .
Reviewing test d~c~mentat"ion to ensure:lhat other.aspects of crane operation were properly tested; and
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- * * *clarifying the scope. and.intent o(WI-MSE-E-07.* *
- .. One viOlation was- identified.' .No *deviation~, unresol~ed, .or* .-irispectio*n
- followup items we~e identified _in this *area. * **
- _ " . .* ..
- *** .: -1.*
- pry Fuet stor*aqe ActiV-ities (42ioo, *a670Q) *
~. . . "' . . . . . .. . . -" , . *' ,..,.
- \\,',"
. The.i!lspector reviewed the lice~see's:inspecfion and m~inten.ance results,.:*
- ._*:for components involved in .heavy-load li.ft applications. for the dry fue1 < * **
storag~ project. Included in: the review were no*ndestructi.ve examination * .. *. (NOE) results of .critical components or highl}" stressed welds*, and * * preveritive maintenance results. on the *spent fuel pool crane (L-3). The 1nspector identified no significant problems.
- -
- The inspector r*evi ewed the licensee's. package of NOE reports documented*
in procedure CLP-M-6, "Inspection of Heavy Load Lift Devices," Rev.2.- .
- The licensee performed vi sua 1 exalili nations (VT), magnetic . part i cl_e * * .
testing' (MT), *and 1 iquid *dye penetrant *examinatiOns (PT) i.n acco.rdance
- with_- the prOCE!dure; on the f() l lowi ".g compo_nents:.
.- . . .. ,,_.. Structur~J Li.d Hoist Rings (VT) -.. ** ~ulti-Assembly Sealed Basket Spread~r Bari (VT)* ~* Multi-Assembly Transfer* Cask Lif.tfngYoke (MT) -: :'* .
-
- _ . -*.
.-:*
- .
Muiti-Assembly Transfer.Cask (MT) . *.: .. -
- Spent Fuel Pool _Crane Main H_ook (PTf: * . *
-~* . . . - .
Spent Fuel Pool Cr~ne Auxiliary Hook (PT)" 18 .-* . .. ~ ."
.*. . **,: ... ** ~~ . . ' . _*.
- ,:
.. These i terns were reviewed with records *for the spen~ fu*e l pocl'l
- crane as ~esc~ibed below.
In addition, the inspector reviewed the licensee's preventive* , mainte_nance records for spent fuel pool crane L-3, last *performed in* .. --.. January 1994 .. The work was performed according to procedure.MSM-M-13,* .. . ** . "Overhead Meehan i cal Crane Inspection,-" Rev .17. . The documentation* showed that most components asso.ciated.with the bridge, trolley;
- auxiliary hofst, .and main hoist were inspected .with satisfactory
res~lts. S~~e. minor items were identified and.dispositioned with work* * ~ _ orders; _The work orders were completed prior to commencement* of dry fuel .: ... * *
- loading.--
.:*
.. .. *:* ... -"N~ *v.i ~*i at ions, d~vi at'ions,. un.resol ved, *. o~ *inspect i.on *iol l owup .items were * ..
- **identified fo this area~
- .. . . .
,.
- _ .
.. -. . : ... ** 8. Report Rev*i ew *
- .*-*
' 9.' .* '* During. the in*spection .period, .the inspectors reviewed the licensee's monthly operating report for May .1994. The. inspectors confirmed that the information pro~ided met the repbrting requiremen~s of TS 6.9.1.t arid Regulatory Guide 1.16, "Reporting of Operating information." **." . . . . . . . . ' . ' ' . ~:N6 violations~ devi~tions, unte~olved, or,inspection.followup items *w~re*- identified in this area. .. . ., .
- ' ::_
Unresolved Items
- ..
- Unresolved items are matters ab~ut whi~h m.ore jnforma~ion is requ}red in - *
order to ascertain whether they are acceptable item.s, viola:tions, or* deviations. Unresolved* items-disclosed during the inspection are. ~iscussed in paragraphs 3.f and 5.b.
' ' . 10. . Meetings and Other Activities (30703).
- .
'. '. Exit Interview (30703) ' . ' . . ' . . . . The inspector~: met with the li~ensee represeiltati~es*d~~oted in* paragrap~ 1 durfng the inspection period. and at the conclusion ~f the * inspection. on June 30, 1994 .. The inspector.s summariied the- scope and results of the inspection and discussed the likely content of. this .. inspection report~ The licensee atknowledged:the information ~nd did not indicate that any of the information disclosed during.the inspection * . could . be considered proprietary_.. in nature~ . -* *
.. ,
- .**"
- 19
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. .. _,. }}