ML18059B196
| ML18059B196 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/08/1994 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18059B195 | List: |
| References | |
| 50-255-94-12, NUDOCS 9409210068 | |
| Download: ML18059B196 (21) | |
See also: IR 05000255/1994012
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I II
Report No~ 50-255/94012(DRP).
.Docket No. 50-255
Licens~e: Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
License Nos. DPR-20
Facility* Name:
Palisades Nuclear Generating Facility
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted:
July 1 through August 19, 1994
. Inspectors:
M. E. Parker
D. G. Passehl
R. L. Hague
J. F. Schapker
C. N. Orsini
K. Salehi
- . Approved By:
f
Sect ion 2A .
Inspection Summary
Inspection from July 1 through August 19,
1994~ Report No. 50-255/94012CDRP)
Areas Inspected:
Routine, unannounced safety inspection by resident and
regional inspectors of actions on previous inspection findings, operational
safety verification, engineered safety feature systems, onsite event
follow-up~ current material conditiorr, housekeeping and plant:,cleanliness~
~adiological controls, security, safety assessment/quality verification,
maintenance, surveillance, engineering and technical support, and dry ~ask
. storage of spent fuel.
Results: Within the 12 areas inspected, no cited violations or deviatioris
were identified.
One noncited violation.was identified (paragraph 7).
The following is a summary of the licensee's performance during this
inspection period:
Plant Operations
The licensee's performance in this area was adequate.
The plant operated at
essentially full power since startup on June 18, 1994 .
~~9210068 940908
. G
ADOCK 0500025 5
..
. ( ..
..
.
.
The licensee's resp6nse to a July 27, 1994, firemain rupture was mixed ..
Operatbrs quickly recognized the situation and deenergized the fire water
pumps to prevent more extensive soil washout and damage to other structures in
the vicinity.
Fire suppression capability wasreturned within a- reasonable
time after as~essing the conseq~ences. of the event.
However, areas requiring
continuous firewatches due to inoperable fire suppression capability were not
adequately established.
The insp~ttor found the lic~nsee's procedures ~nd*
training in thi~ regard were lacking.
The licensee's response to an August 9, 1994,:ov~rflow of wa~er from the valve
pit adjacent to the Primary System Storage Tank and the Utility Water Storage
Tank was good.
Operators and health physics personnel took immediate steps to
identify and isolate the leak.
There was an adverse trend in Chargin.g Pump P-55A availability due to material*
condition deficiencies. *Several times during the past summer the pump has
been inoperable, causing an increased out-of-service time to necessitate
- repairs.
- rhe licensee's actions on monitoring and evaluating Dose Equivalent Iodine
were satisfactory.
The current average monthly activity level is
approximately 0.045 microcuries per milliliter. The licensee has secured the
services of two tontra~tors in its "fuel integrity working group," that meets
regularly to review and discuss the data.
Safety Assessment/Quality Verification
Consumers Power Company's Management.and Safety Review Committee {MSRC) for
the Big Rock Point and Palisades nuclear plants met on June 29, 1994.
The
members met to discuss recent plant ope,rations, outages, internal assessment
findings, program changes, and future schedules.
Issues were discussed based
on plant tours, interviews, and discussions with various licensee personnel ..
The MSRC made several positive 6bservations and suggestions for improvement at
the meeting.
Maintenance and Surveillance
The licensee's performance in this area was adequate .. *The licensee continued
to experience problems with the ~ain Generator Voltage Regulator Firing .
Circuit.
Altho~gh work to disable the west firing circuit module trip was
effective, there have -been other spurious alarms associated with the ma-in
generator control-circuits showing that equipment problems still exist.
Engineering and Technical Support*
The licensee's performance .in this area was adequate.
The inspectors met with
licensee representatives working the alternate spent fuel pool cooling
project. The licensee appears to ha~e adequate measure~ in place to assure a
successful completion of the prbject. *
- .*
2
Dry Cask Storage Of Spent Fuel
The licensee's performance in this area was adequate.
was issued for failing to provide double verification
analysis of the boron concentration of the spent fuel
cask loading.
A noncited violation
for sampling and ..
pool water during dry
On July 28, 1994, the licensee identified three minor iridications o~ the
multi~assembly scaled basket (MSB) #4 ihat were nbt identified d~ring the
original review of the radiographs.
The licen~ee subsequently performed an
oper~bility evaluation and determined that the MSB #4 was operable. This
determination was based upon testing performed on the MSB prior to it being
placed into service on the storage pad.
The licensee was in the process of*
completing a more detailed operability assessment that includes a fracture
analysis .. The licensee is making plans to unload the MSB.
Dose rates higher than expected were identified on Ventilated Concrete Casks_
(VCC) #3 and #4 after loading.
The highest dose rate for VCC #3 was 60
mrem/hr (0.6 mSv/hr), and for VSC #4 was 56 mrem/hr (0.56 mSv/hr).
The
licensee followed the required actions of the license, which included
verifying the correct fuel* loading and performing an analysis to demonstrate
compliance with 10 CFR Part 20 and 10 CFR Part 72 with regard to dose to the
general public. These r~quirements were completed satisfactorily.
Improvements were observed duri~g loading of multi-assembly sealed basket
(MSB) #4 over the previous loading of MSB #3.
There was better prep~ration
and planning, greater control over the assigned tasks, enhanced communication,
and more direct manage~ent oversight. Radiological cont~ols were effectively
implemented during loading and handling operations. Contamination control *
practices were generally gopd.
3
1.
. DETAILS
Persons Contacted
Consumers Power Company
- R. A. Fenech, Vice President, Nuclear Operations
- T. J. Palmisano, Pl ant General Manage'r *
W. F. Peabody, NECO Manager (Interim)
- R. 0. Orosz, Director, NOD Services
- R. M. Swanson, Director, NPAO
- 0. 0. Hice~ Nuclear Training Manager
- s: Y. Wawro, Acting Operations Manager
- Or W. Rogers, Safety & Licensing Director
R. B.
Kasper~ Maintenance Manager
- R. C. Miller, System Engineering Manager
- K. M. Haas, Radi6logical Services M~nager
C. R .. ~itt, Administrative Manager
- J. C. Griggs, Human Resource Director
- H. A. Heavin, Controller
M. A. Savage, Corporate Communications
- 0. G. Malone, Shift Operations Superintendent~
0. J. Malone, Radiological Services Supervisor
- T. P. Neal , *Heal th *Physics Support Superintendent
. #R. A. Vincent, Licensing Administrator
- J. Decker, General NOT Supervisor
- 0. Fadel, NECO Engineering Program Manager
'*
- M. Ferens, NECO Ory Fuel Storage Procurement Manager
- S. Maclean,. NECO Ory Fuel Storage Engineer - ';
,--~*
- J, Nordby, NECO Welding Engineer *
- *'. *
- J. Pomaranski, NECO Construction Manager
- R. Smedley, Licensing Staff Engineer
- 0. Zeigler, NOT Fi~ld Services Supervisor.
Nuclear Regulatory Commission*
- W. J. Kropp, Reactor Projects Section Chief
- M. E. Parker, Senior Resident Inspector
- D. G. Passehl, Resident *inspector
- C. Haughney, .Branch Chief, NMSS
- S. O'Connor, Team Leader, NMSS
- J. ~mith, Reactor Inspector, Riii
- Denote~ those* attending the exit interview conducted on August 19,
1994.
- Denotes those attending the exit interview c~nducted on August 3, 199t ....
The inspectors also had discussions with other licensee employees,
including members of the technical and engineering staffs, reactor and
auxiliary operators, shift engineers and electrical, mechanical and
instrument maintenance personnel, and contract security personnel.
4
.* .. :*****
2.
Action on Previous Inspection Findings {92701)
a..
{Closed) Inspection F6llowup Item 255/91009~01CDRP):
Mainte~anc~
personnel used an uncontrolled copy of a vendor manual during a
maintenance activity to disassemble and clean a raw water
- strainer.
No Notice of Violation was issued:.because this was
considered an addition~l example of ~ violation issued in
Inspection Report 255/91006{0RSS) involving use of uncontrolled
vendor manuals.
Closure of this issue will be tracked under
.
violation 91006-03{0RSS}, which is still open and will be reviewed
for closeout.at a later date. This item is closed.
b.
{Closed) Inspection Followup Item 255/92006-0lCDRPl:
Concrete
spalling in auxiliary feedwater {AFW) pump room.
This item
- concerned the licensee's evaluation of the impact of feedwater
heater E-4A settling on the integrity of the AFW pu~p room.
The
inspector's review of this issue was documented in Inspection
Report 50-255/92027{0RP).
This item is closed.
c.
<Closed) Inspection Follo~~P Item 255/92021-0lCDRPl:
Steam leaks
in vents for reheaters. This item was opened to track the
licensee's root cause determination ~nd corrective action for .
accelerated steam erosion of the vent header piping on feedwater
heaters E-6A and E-68.
The licensee's reviewdetermined ... thatthe *
tunning vent configuration was changed *during iristallation of new
E-6A/B feedwater heaters in 1990.
At that time, the vent~ were
modified to combine three 1" running vents into a single 1"
running vent. This l" running vent dis~harged into a 3" vent
header. Since the single running vent.passed the same flow, 1 to
2 percent of the steam supplied to the heaters, the velocity in.
this line was increased by a factor of three .. The running vent
entered the header at a 45° angle, which contributed to the ,.steam
cutting at the pipe wall.
The licensee has implemented several correcti~e actions that
i.ncl uded:
- ,
The schedule 40 carbon steel vent header piping was replaced
with schedule 160 stainless steel. This increased the wall
thickness and erosion resistance of the piping.
The running vent was modified to enter the vent header albng
the centerline, thus eliminating steam cutting at the header
wall.
Operations procedures were changed to keep the running vents
closed during startup and normal power operation, and to
open the running vents once per month for a six hour purge .
of the heaters.
5
.,
The licensee has been monitoring the heaters as part of the
Thermal Performance Monitoring Program to ensure that the heat,ers
do not become air bound.
No adverse affects of the modification
and th.e procedure change have been identified by the licensee.
This item is closed.
No violations, deviations, unresol~ed, or inspection followup items were
identified iri this area.
3.
Plant Operations (71707, 93702)
The plant has operated up to 100 percent power since startup on June 18,
1994.
a.
Operational Safety Verification (71707)
The inspectors verified that the facility was being operated in
conformance with the license and regulatory requirements and that
the licensee's management control system was effective in ensuring
safe operation of the plant.
On a sampling basis, the inspectors
verified proper control room staffing and coordination of plant
activities; verified operator adherence wtth procedures and
technical specifications; mon1tored control room indications for
abnormalities; verified that electrical power was available; . .--,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 control room shift
-turnovers.
The turnovers were conducted in a professional manner
and included log reviews, panel walkdowns, discussions of*
maintenance and surveillance activities in progress or planned,
and associated LCO time restraints, as applicable.
b.
Engineered Safety Feature lESFl Systems (71707)
During the inspection period, the inspectors selected accessible
portions of several ESF systems to verify status. Consideration
was given to the plant mode, applicable Technical Specifications
(TS), Limiting Conditions for Operation (LCO) requirements, and
other applicable requirements.
.
.
Various obser~ations, where applicable, were ~ade of hangers and
supports; housekeeping; whether freeze protection, if required,
was installed and operational; valve position and conditions;
potential ignition sources; major component labeling, lubrication,
cooling, etc.; whether instrumentation was properly installed and
functioning and significant process parameter values were
consistent with expected values; whether instrumentation was
calibrated; whether necessary support systems were operational;
and whether locally and remotely indicated breaker and valve
positions agreed.
6
"'"'*'**::
During th~ fnspection, the accessible portioris of the High
Pre~sure Safety Injection and Low Pressure Safety Injection were
-walked down.
_ The following items were identified during the walkaowns:
A pipe support on the miniflow recirculation line for high
pressure safety injection pump.P~66A was missing.
Protective grating around a floor penetration for a sensing
line for pressure transmitter PT-0306 (low pressure safety
injection pump discharg~ pressure) was lifted from the floor
and resting on the~ inch sensing line.
In response to the above items, the licensee ~valuated the
conditions and took apprbpriate ~ction.
c.
Onsite Event Follow-up (93702)
During the inspection period, the licensee experienced several
events, some of which required prompt notiffcation of the NRC
pursuant to 10 CFR 50.72.
The inspectors pursued the events -
ohsite with licensee and/or other NRC officials.
In each case,
the inspectors verified that any required notification was.:~correct
and timely.
The inspectors also verified that *the licensee
initiated prompt and appropriate actions.
The specific events
_were as follows~
Fire Main Rupture:
On July 27, 1994, the firemain system
- ruptured underground at the south end of*the ~creen-house
.building. *The rupture caused the loss of all automatic fire
suppression ~apability throughout the plant. Jhe ltcensee-
implemented several contingency actions, such as notifying
the Covert fire department, increasing plant fire tours, and
canceling a preplanned outage on an emergency diesel
generator.
By midnight the licensee identified the location -
of the break to be just downstream of ffre water to cooling
tower isolation valve.MV~FP-176. The licensee closed the
valve thereby isolating the break. Automatic fire
suppression capability was returned sho~tly thereafter to
all areas of the plant, with the exception ot the cooling
towers and some nonessential areas.
The ruptu~e caused a buckling of the ground surface above
the failed section of pipe and washout of soil in the
vicinity of the break location. A concrete pillar
supporting the 90 inch cooling tower return line, located"
near the center of the newly-formed 12 foot diameter sink
hole, remained unaffected.
No movement of the cooling tower
support was noted to date.
The licensee has been monitoring
the line for any movement since the event occurred.
7
..
The licensee determined the probable *cause of ttie failure
was bending and twisting forces at the failure location due
to cyclic loading from heavy loads on the ground above,
- combine.d with the more brittle nature of the pipe material
(Grade D cast iron).
Repairs include replacing the.section of~fail~d pipe with a
. stronger, more ductile pipe material, and restoring the
affected soil to proper design compaction ..
The inspector found the license~'s response to this event to.
be mixed.
The licensee's immediate response was g.ood ..
. 0-perators quickly recognized .the situation and deenergized
the fire water pumps to prevent more extensive .. soil washout
and damage to other structures in the vicinity. Fire
suppression capability was returned within a reasonable time
after assessing the consequences of the event.
However~ areas requiring ~ontinuous firewatches doe to
inoperable fire suppression capability were not adequately
established. The inspector found the licensee's procedures
and training in this regard were lacking~~ Tha weaknesses in
the licensee's procedures and training in thii area is
considered an Inspection Followup Item pending, further
review by the NRC (255/94012-01).
Overflow Of Slightly Radio~ctive Wate~ From The Utility
Water Storage Tank:
On August 9, 1994, the licens~e
discovered an overflow of water from the valv~ pit adjacent
to the Primary System Storage Tank and the Utility Water
Storage Tank, T-90 and T-91 respectively. Subsequerit
evaluation determined that the water was coming from.tank
T-91, which receives distillate from the .dirty waste
evaporator. Health Physics took immediate action to rope
off the area and obtain soil sa~ples. Soil samples around
the tank where the overflow occurred indi~ated low levels of
activity. The licensee has removed some contaminated soil*
and is.continuing to perform a more detailed radiation
survey to determine the extent of contamination.
Once the
valve pit was pumped down, the licensee was able to
determine that the leak was on a recirculation line.jn the.
valve pit.
In additi~n, the licensee retracted the following telephone
notifications made earlier. to the NRC:
Control Room Heating. Cooling~ and Ventilation CHVAC) System
Failed To Meet Design Basis Flow Requirements:
On May 22,
1994, a non-emergency 4-hou,r report was made based on the *
results of the service water flow test for the control room
HVAC coolers. The report stated that the flow required to
8
- * ..
support the service water temperature analyzed upper limit
of 81.5 degrees F at 46 gpm was not met during the testing.
The test results showed flows through HVAC condensing units
VC-10 at 45 gpm, and VC-11 at 44 gpm;
The condition was*
reported.per 10 CFR 50.72(b)(2)(iii) and under 10 CFR
50.72(b)(2)(i).
.
.
After further reviews, the licensee deter~ined that the*
plant would not have exceeded the design basis, andthe
control room HVAC coolets would have been able to perform
their design basis function.
This was based on the s~rvice
water fl ow data and the 1 ake temperature dl,lri ng the 1 ate
fall and winter time period when the low flow condition
existed concurrent with the unit at power.
The 1 icensee had November temperature data that showed the .
lake water temperature at approximately 50 degrees F.
Therefore, ample margin existed in the service water
temperature to make up for the apparent 1-2 gpm drop in
service water flow.
Emergency Diesel Generator (EOG) Potential Overload:
On
April 27, 1994, a non-emergen~y 4-hour report ~as made when
the licensee found that the potential eiisted for the EOG to
exceed the two hour rating if emergency sa f eguards.,,system
pumps were all operating at run-out conditions concu~rent
with a Loss of Cotilant Accident with a Loss of Offsite Power
and only one EOG operating.
The condition was reported per
The licensee. subsequently determined that the inputs for the
time to initiate manual loading of a hydrogen recombiner and
.a second battery charger were not realistic. The licensee
concluded that there would be 30 minutes into the event *
befote the hydrogen recombiner was put in operation and the
second battery charger would not be energized until after
one hour into the event.
W~th this information the EOG loadirig calculation w~s
revised and resulted in a total load within the two hour
rating.
- d.
Current Material Condition (71707}
The inspectors performed general plant as well as selected system
and component walkdowns to assess the general and specific
material condition of the plant, to verify that work requests had
been initiated for identif;ed equipment problems, and to evaluate
housekeeping.
Walkdowns included an assessment of the buildings,
components, and systems for proper identification and tagging,
accessibility, fire and .security door integrity, scaffolding,
radiological ~ontrols, and any unusual conditions. Unusual
9
- .*
conditions included but were not limited to water, oil, or other
liquids on the floor or equipment; indications of l~akage through
ceiling, walls, or floors; loose insulation; cofrosion; excessive
noise; unusual temperatures; and abnormal ventilation and
lighting ..
.
.
'
.
Material tondition this inspection period was generally good,
b~t
some areas warrant continued attention, including Charging Pump
P-55A.
The inspector noted an increase in equipment problems
associated with P-55A over the past few months. *The licensee has
been unable to obtain an acceptable seal package for the pump .
. The pump has leaked excessively several times during the past.few
months necessitating repairs and challenging the TS LCO.
There have been other problems with the pump as revealed by a
re~iew of control room logs.
The inspector reviewed the control
room logs for the past three months and noted in the past two
months alone the pump ran for ~nly 15, 16, and 11 days,
respectively, before being declared ~noperable for repacking.
Historically, the pump would run for approximately two months
before repacking became necessary. Other noted deficiencies
throughout the period included:
Loss of automatic speed control;
Pieces of RTV sealant floating in the plunger well
a~ea; *
Unexplained b~nging hoises in the fluid drive section near
the pump discharg~;
Clattering of the discharge check~valve.
Although some of the problems, such as the short life of the
packing, appear to be design related; other problems were due to
questionable maintenan~e work practices that led to maintenance
rework-.
Involvement by engineering was satisfactory. The
inspectoi found the system engineer appropriately involved with
resolution of the design discrepancies.
The material condition of
Charging Pump P-55A is considered an Unresolved Item pending
further review by the NRC and licensee (255/94012-02} .
- . M
Considering the previous problems with the material condition of
the charging pumps, the licensee has agreed to respond to this
Unresolved Item within 60 days of receipt of this letter .. The
response should address what actions the licensee plans to take to
improve the material condition of the charging pump and to reduce
the.out-of-service time and potential challenge to the T.S. LCO.
e .. *Housekeeping and Plant Cleanli~ess (71707}
The inspectors monitored the status of housekeeping and plant
cleanliness for fire protection and protection of safety-related
10
. .
f.
equipment from intrusion of foreign matter~ :* .. No significant
concerns were identified this inspection period .
Radiological Controls (71707)
The inspectors verified that -personnel
were~;.fol lowing heal th
physics procedures for dosimetry, protective clothing; frisking,
post~ng, etc., and randomly examined radiation protection
instrumentation for use, operability, and c~libration.
The inspectors reviewed the licensee's current action on Dose
Equivalent Iodine (DEi).
Dose equivalent iodine values .. are,.us.ed
as an indicator of failed fuel.
The current average monthly
activity level is. approximately 0.045 mitrocuries per milliliter.
The TS have an upper limit of 1.00 microcuries per milliliter
before plant shutdown is required.
The current DEi value has placed the plant in the second of fouf
"Action Le~els" (0.03 < DEi < 0.12) per plant procedure COP-1,
"Primary Coolant System Chemistry." At t~is_ level the licensee is
required to increaseprimary coolant sampling frequency to daily,
and to evaluate the efficiency of the Chemical Volume and Control
System demineralizers.
The iicensee has performed these actions
in addition to several others, including review of .chemt.stry*data
by outside contractors, NWT and Siemens Power Corporation.
The
two contractors-are members of th~ licensee's "fuel integrity
working group," that meet reg~larly to review and discuss the
data.
.
The current position of the group is that there is between one and
three leaking fuel rods in the core, likely in a second cycle "N"
fuel assembly.
The inspectors found that the licensee is taking appropriate
actions to track and evaluate the data. * The group has predicted
that based on current trends, the DEi activity level should be
about 0.08 microcuries per milliliter at the end of this cycle.
g.
Security (71707)
. Each week during routine activities or tours, the inspectors
monitored the licensee's security program to ensure that observed
actions were being implemented according to the approved security
plan.
The inspectors noted that persons within the protected area
displayed proper photo-identification badges and those individuals
requiring escorts were properly escorted. The inspectors also*
verified that checked vital areas were locked and alarmed.
Additionally, the inspectors also observed that pe~sonnel and
packages entering the protected area were searched by appropriate
equipment or by hand.
. 11
No violations, deviations, unresolved, .or inspection followup items were
identified in this area.
4.
Safety Assessment/Quality Verification {40500 and. 92700)
Consumers Power Company's Management and Safety Rev*iew Committee {MSRC)
- for the Big Rock Point and Palisades nuclear plants met on June 29,
19.94.
The members met to discuss recent pl ant oper.ati.ons, outages,
internal assessment findings, program changes, and future schedules.
Issues were discussed based on plant tours, interviews,.and discussions
with various licensee personnel.
The MSRC made several positive
obser~ations and suggestions f6r impro~ement.
No violations, deviations, unresolved, or inspection followup items were
identified in this area.
5.
Maintenance/Surveillance {62703 and 61726)
a.
Maintenance Activities (62703) .
Routinely, station mainten~nce activities w~re observed and/or
reviewed to ascertain that they were conducted in accordance ... with
approved.procedures, regulatory guides and industry codes or
standards, and in conformance with technical sp~cifi~ations.
The following items ~ere also considered during this review:
LCOs
were met while components or systems were removed from service;
, approvals were obtained prior to initiating' the work; functional
testing and/or calibrations were perfor~ed prior to returning
- components or systems to service; quality control records were*
maintained; and activities were accomplished by qualified.
personnel.
The inspectors were concerned with the large number (approximately
1800) of outstanding non-outage corrective maintenance work orders
in the licens~e's backlog.
The licensee was aware of the issue
and has begun steps to address.the issue.
The inspectors will
continue to follow the licensee's progress in resolving the
backlog.
Portions of the following maintenance activities were observed or
reviewed:
Work ~nstruction WI-24413037-02:
Disable Main Generator *
Voltage Regulator Firing Circuit Module Trip: Workers used
the work instruction and Temporary Modification TM-94-072 to
disable the west firing circuit module trip in the main
- generator's voltage regulator to avoid an unanticipated
turbine/reactor trip. The work was performed by electrical
maintenance personnel with support from system engineering.
The quality of support for this job appeared good.
The
12
.
- .:;
.
.
licensee had extensive vendor input and held discussions
with other nuclear utilities that had experiented similar
problems.
The job was performed satisfactorily.
However, there have been other spurious alarms associated*
with the main generator control circuits that indicate
- equipment problems still exist. The licen~ee appears to
have taken appropriate followup actions, includi~g
continuous monitoring ~f suspect component~. .
Work Orders 24412845. 24411704. 24413113. 2441-3114.
24413145. and 24413782: Addresses various Charging Pump
P-55A deficiencies which is further discussed in paragraph
3.d of this report.
- Work Order 24413584:
Repair fir~ main rupture which is
further discussed in paragraph 3.c of thi~ report~ *
Work Order 24413217 and 24413262:
Resolve TI-0122HA, "A"
.Hot Leg Temperat~re Indication Fluctuations
Work Order 24410670:
Load and Transport Multi~Assembly
Sealed Basket {MSB) No. 3
Work Order 24410664:
Load and Transport Multi-Assembly
Sealed Basket {MSB) No. 4
- Work Order 24413278:. Lower High Temperature Alarm Setpoint.
Per.Temporary Modification 94-069 From 175 to 147 Degrees F
on Primary Coolant Pump P-50D
- Work Order 24412785:
Erect Masonry Block Wall,around:.fuel
Oil Transfer Pumps PISA and Pl8B for Seiche Protection
b.
Surveillance Activities {61726)
During the inspection period, the inspectors observed TS required
surveil 1 ance testing and verified that testing was p.erformed in *
accordance with adequate procedures, that test instrumentation was
calibrated, that results conformed with technical specifications
and procedure requirements and were reviewed, and that any
deficiencies identified during the testing were properly resolved.
The inspectors also witnessed or reviewed portions of the
following surveillances:
M0-7A-2. "Emergency Diesel Generator 1-2 CK-68))" Rev.31
FPSP-M0-1. "Fire Suppression System Valve Alignment." Rev.6
MI~6. "Ar~a Monitor Operational Check." Rev.I
13
No Violations, deviations, unresolved, of inspectio~'followup items were
identified in this area.
- 6.
Engineering and Technical Support {37700)
7.
The inspectors met with licensee representatives working the alternate
spent fuel pool cooling project.
The purpose of the project w~s to
upgrade the material condition of components {Valves, piping, etc.)
.associated with the spent fuel pool cooling systems and component
cooling water cooling systems during the next refueling outage in 1995.
The discussions centered on the system design and layout, design
contingencies, and preriminary work plan.
The licensee appears to have adequate measures in place to assure a
succe~sful completion of the project.
The alternate cooling system is
scheduled to be in effect for about thirty days when there would be
minimal heat load in the spent fuel pool.
The 'portions of the system
that were in safety related areas of the plant would meet seismic
requirements, materials would be certified to appr6priate standards
where appropriate, and a backup class lE power supply would be
available.
Procedures were in place to o~erate and maintain the system
during normal and off-normal conditions.
The inspectors will continue to periodically monitor the licensee~.s
progress on this project.
No violati6ns, deviat~~ns, unresol~ed, or inspection followup items were
identified in this area.
Dry Cask Storage of Spent Fuel (83750, 37700)
The inspectors monitored the licensee's loading -0f ~pent fuel assemblies*
from the spent fuel pool fuel storage racks to the dry cas*k 'MSBs.
This
inspection covered loading of two dry casks, Nos. 3 and 4.
Dry Cask No.
3 was loaded on June 20, 1994, and Dry Cask No.4 was loaded on July 11, *
1994.
Although overall the loadings were performed successfully,
several weaknesses were observed with loading of MSB No.3, whereas
loading of MSB 4 was greatly improved.
a.
Background
The licensee contracted with Pacific Sierra ~uclear Corporation
{PSN) to design and construct a dry cask spent fuel storage
facility to be partially constructed onsite for long term
temporary storage of spent fuel.
The licensee has documented a 10
CFR 50.59 evaluation as required by 10 CFR 72.212 (Subpart K),
showing that use of the general license for storage of spent fuel
at the power reactor site will not involve an unreviewed safety
q~estion or Technical Specification (TS) change.
The PSN cask design consists of a steel m~lti-assembly sealed
basket (MSB) which holds 24 spent fuel assemblies {sealed) and a
14
.*:*
steel clad ventilated concrete cask {VCC) which provides
biological shielding and MSB protection.
The PSN cask design has** been granted a Certificate ot' Compl hnce
{C of C) by the NRC.
This inspection was conducted using the
.
specifications, standards, codes, and commitments described in the
licensee's design certification.
b.
Radiological and Fuel Handling Observations For MSB No. 3
The inspectors observed radiological practices and monitored the
loading of 15 spent fuel assemblies from the spent fuel pool to
MSB 3 on June 20, 1994.
Radiological controls were generally
good.- In the area of fuel handling,, there were several concerns
identified due to poor preparation and a lack of ownership by.
operations personnel;
Radiolrigical control.s during loading ot MSBJ were effectiv~ly
implemented during loading and handling operations. Contamination
control practices were generally good.
There were some problems
with personnel walking pastcoritaminated area boundaries without
the proper protective clothing. This was caused when the boundary
was moved as the multi-assembly transfer cask (MTC) and MSBwere
1 ifted. from the fue 1 poo 1 to the cask wash down pit;**.:. The' 1-icensee
indicated that the posting criteria would be reviewed .for the job
. to determine if a more effective means could be implemented for
- future cask 16ading operations..
During reviews of fuel handling operations for the loading of MSB
No. 3 on June 20, 1994, the inspectors identified the following
concerns:
The spent fuel pool boron was not sampled in accordance with
the C of C requirements. A violation was issued {paragraph
7.c);
Operators worked up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to accomplish the activity
in a high temperature and high humidity environment. This
increased the likelihood for error;
Communications and video recording gear were not properly
prestaged prior to loading fuel, causing unnecessary delays;.
A hose used to fi 1 ter spent fue 1 poo 1 water was found to
interfere with movement of the fuel handling machine and had
to be re-located, causing extra effort to control
contamination and unnecessary delays;
Some contamination boundary postings were i neons pi cuous as .
described above.
15
These* concerns were discussed with the licensee. During
subsequent loading of MSB No. 4 on July 11,
1994~ the inspectors
- did not identify any similar concerns. *The inspectors noted_ that
the lit~nse~:took extensive measures to addr~ss these concerns,
including dedicating a senior reactor operator to be in overall
contrbl of fuel loading activities. The inspectors considered the
licensee's actions to correct the above concerns noted during the.**
loading of MSB No. 3 ~s effective.
c.
Violation For Inadequate Boron Sampling of the Spent Fuel Pool
The C of C for dry cask fabrication and loading required the *
licensee to sample and analyze the boron contentration of the
spent fuel pool water within four (4) h~urs of setting the first
fuel assembly in th~ MSB.
The require~ent mandated double
verification for sampling and a~alysis. Specifically, double
verification required two independent technicians take samples and
perform independent analyses. Contrary to this requirement,
during loading of MSB N6. 3, the li~ensee identified that ~
routine sample was taken and analyzed by only one technician.
Although the licensee took three separate .-.samples between 2: 05
p.m. and 7:17 p.m. (the time of the first~fuel assembly loading),
the samples were not taken by two persons and were not *
independently analyzed.
,
A potential contributor to this problem was that Chemistry
Department personnel were unaware of the requirement.
This
requirement should have been provided by the Operations
.
Department, who had the overall responsibility of loading MSB 3.
The first sample taken at 2:05 p.m. was*a**routine sample reported
by Chemistry to the Control Room.
Procedure FHS0-17,
"Multi-Assembly Basket Loading Procedure," Section 3' *. 3, did not
require double verification~ therefore, this sample should not
have been used to meet the C of C requirement:
In fact, norie of
the three boron samples met the C of C requirements for
independent verification.
On the following day, d~ring the review
of sampling records and procedure requirements, the licensee
iden.tified this problem and initiated condition*-,report
C-PAL-94-0409.
10 CFR 72.210 requires the licensee to comply with the
requirements specified in the C of C pertaining to storage of
spent fuel assemblies.
Further, 10 CFR 72~212(b)(2)(i) requires
that conditions set forth in the C of C must be met prior to ~ /
- loading fuel.
Not meeting the specific requirement for double
verification during the sampling of the SFP, as delineated in the
- C of C, constituted a violation of 10 CFR 72.212(b)(2)(i).
In
considering the violation, the enforcement discretion criteria
specified in 10 CFR Part 2, Appendix C, Section VII(B)(2) was
- considered.
16
d.
This violation will not be subject to enforcement *action because*
...
the licensee's efforts in i dent i fyi ng and correcting the vi o lati"on
met the above enforcement criterfa. Corrective actions included .
revising the governing procedure for dry cask loading with
adequate cautions concerning double verification.
In addition,
- the licensee counseled responsible department\\personnel and other
involved individuals. Double verification of .the boron was
performed during t'he loading of MSB No. 4.
Adequate .checks exist
to preclude reoccurrence during subsequent cask loadings.
Fuel Handling Observations During Loading of MSB No. 4
- The loading of-MSB 4 was performed on July 11, 1994, with.
significant improvement from MSB 3 loadi~g activities.
The *
inspectors* observed loading of 24 fuel
a~semblies into MSB 4. The
improve~ents reduced the overall length of the activity to less*
than a third of the time consumed during the prior cask loading.
These changes reflected better pre~araiion and planning, greater.
control over the assigned tasks, enhanced communication,. and more
di re ct management oversight. Proper ownership of this acnv*ity
was evident from its start to its completion_
Various steps were
preplanned and were properly ~oordinated.
e.
Welding Inspection
The NRC inspector observed the welding* of the seal lid and
structural lid of the MSB Nos. 3 and 4.
The following was
verified:
The essential welding variables were controlled i~
accordance with the applic~ble welding procedure
.
specifications (WPS FC-LID revision 4 (FCAW)
and;SM~L1D
revision 2 (SMAW)).*
The welding p~ocedure specifications and welders and welding
operators were qualified in accordance with the
specification requirements.
- .The helium leak test was performed in accordance with the
specification requirements.
The certified material test reports for.the welding
materials were reviewed.
The welding wire and electrodes
met the requirements of the applicable American Society*of
Testing Material (ASTM) standards.
The licensee's middle management supervis1on was apparent
throughout the welding and te.sting of the MSB seal and structural
l ids.* A 11 processing observed was performed in accordance with
procedure requirements. *
17
f.
Elevated Dose Rates Found On MSB 3 and MSB 4
There were higher than expected radiation measurements when the
loaded MTC and MSB were lifted out of the spent fuel pool.
The
licensee attributed the higher reading to a new:step in their
procedure* which required draining 75 gallons of**water from the
MTC/MSB as it was being lifted. This step was added to lower the
water level in the MSB so the water would not interfere with
subsequent welding of the lid to the MSB.
This reduced the
shielding effect of the water in the MSB which was compe*nsated for
by us.ing shielding during the 1 id welding. *
When the MTC/MSB assembly was loaded into the Ventilated Concrete
Cask (VCC), further radiation dose rate surveys were required
. prior to moving the VCC to the storage pad.
The results of these
- surveys indicated that some areas on the top of the VSC exceeded
the maximum dose rate of 50 mrem (0.5mSv/hr) prescribed by the C *
of C. The highest dose rate identified was 60 mrem/hr (0.6
mSv/hr).
The licensee followed the required actions of .the C of C
which included verifying the correct fuel Toading and performing
an analysis to demonstrate compliance with 10 CFR Part 20 and 10
CFR Pa~t.72 with regard to dose to the general public. These
requirements were completed satisfactorily. *
A further detetmination of why the observed dose ~ates exceeded
those originally predicted was also performed. This analysis**
stated that the dose rate predictions were based predominat~ly on
radiation emanating from spent fuel with a giv~n burn-up and age;
however, the licensee believed that early fuel assemblies
contained varying amounts of Cobalt (Co )-60 in* *the top hardware.
The Co-60 was produced by neutron activation of Co-59 which was a
trace element in the assembly hardware. The concentration of-.Co-59
was not controlled until recently and could vary significantly
from assembly to assembly.
Elevated dose rates were also ide~tified on VCC No. 4.
The
highest dose rate was 56 mrem/hr (0.56 mSv/hr). A NRC Region III
radiation specialist was sent to the site to make confirmatory
surveys on VCC No. 3.
In addition, the results for VCC No. 4 were
reviewed.
The results of these surveys wer~ in agreement with
those of the licensee.
The shielding analysis for the cask
assumed a uniform plane source of 50 mrem/hr{.5 mSv/hr) emanating
from the top of th~ cask.
A 29 point survey performed *on the top*
of VCC 3 showed an average dose rate of 28.9 mrem/hr {.29 mSv/hr).
Similar results were obtained for VCC 4; ther~fore, the dose to
the public from VCC No. 3 and No. 4 was enveloped by the original
shiel~ing analysis.
In July 1994, the NRC's Office of Nuclear Material Safety and .*
Safeguards conducted an audit of manufacturing activities of the
cask vendor, Sierra Nuclear.
The results of this inspectibn are
documented in Inspection Report 94207. Several quality assurance
18
issues were identified involving manufacture of the fifth through
the ninth casks.
As a result of these-concerns, the licensee
elected to perform a re-review of fabrication documents associated
with the four casks previously loaded.
-
O~ July 28, 1994, during a re-review of the radio~raphs for the*
multi-assembly sealed basket (MSB), the licensee identified three
indications on MSB No. 4 that were ncit.identified in the origi~al
~eview of radiographs. *The indicati6ns were characterized as
follows:
1) 3/4 inch linear longitudinal indication off center
line of weld,
2) 5/16 inch traverse linear indication off center
of weld, and 3) 3/8 inch linear longitudinal indication .on edge .. of
weld.
Upon di~covery of the indications, the licensee subsequently
- performed an operability evaluation and determined that the MSB
No.4 was operable. Thts determination was based upon testing
performed on the MSB prior to being placed into service on the
.*
stor~ge pad.
The testing consisted of a hydro pressure test and
vacuum drying with 30 minutes hold times. :Based* upon the above
testing the licensee concluded that a thru-wall crack did not
exist.
In addition, no fatigue loading exists and, therefore,
there .are no forces present to propagate the present indications.
The 1 iCensee is working with the cask manufacturer, ~*Sierra *Nuc1'e*ar * *
Cqrporaticin, to perform a detailed finite analysis to assure
continued interim operability ts not affected.
(See paragraph 9.a
for additional information.)
The licensee is developing plans to return MSB No. 4 to the spent
fuel pool area where.the fuel will be unloaded and re-lbaded into
- another cask.
One non-cited violation was identified in this area.
No deviations,
unresolved, or inspection followup items were identified.
8.
Report Review
During the inspection period, the inspectors r~viewed.the licensee's~
monthly operating report for June and July 1994.
The inspectors
confirmed that the information provided met the reporting requirements
of TS 6.9.1.C and Regulatory Guide 1.16, "Reporting of Operating
information."
No violations, deviations, unresolved, or inspection followup items"were-:
identified in this area.
8.
Unresolved Items
Unresolved items are matters which require more information in order to
ascertain whether it is an acceptable item, an open item, a deviation or
. a violation.
One unresolved Items was disclosed during this inspection
is discussed in paragraph 3.d.
19
...
9.
Inspection Follow-up Items
In~pector follow-up items are matters which have been discussed with the.*
licensee, which will be reviewed by the inspector, and which involve
some.action on the part of the NRC or licensee rir both.
~one Inspection
Follow-up Item disclosed during the inspection is discussed in paragraph
3.c.
10. * Meetings and Other Activities
a.
Management Meetings {30702)
A meeting was held between the licensee and the NRC at the
Palisades Site on August 3, 1994, to discuss Consumers Power
Company's {CPC's) Fabrication Validation Plan to verify
acceptability of the multi-assembly se~led baskets {MSB) .f6r the.
VSC-24 dry spent fuel storage system that were presently onsite~
CPC personnel briefed NRC on the Validation Plan, the
implementation of the Plan on MSB No.
6~, lssues identified. during
the validation process, and resolution of the issues.
The
briefing consisted of background information leading to the need
for the Validation Plan, results from reviews of material
deficiencies on MSB Nos. 6, 7, and 8, and results *from CPC*'vendor *
surveillance/audits.
Implementation of the Validation Plan was
not complete as bf the date of the briefing.
The need f6r the Plan w~s identified through results of a Quality*
Assurance {QA) inspection conducted by NRC and audits conducted by
.utilities of the MSB fabricator, Sierra Nuclear Corporation {SNC).
From this information, CPC determined that there was a need to
conduct this validation program.
CPC created a checklist/matrix to document the verification of
certain critical dimensions, weld quality and weld material
traceability, the existence of certified material test reports,
the use of approved suppliers, and other quality attributes in the
fabricati~n of MSB Nos. 1 through 10.
In addition, CPC set up a radiographic film reader to all-0~ NRC to
review radiographs of the MSBs.
Approximately half of the *
radiographs for MSB No. 4 were reviewed by NRC.
Based on the information presented during the briefing to NRC, and
providing that the implementation of the Fabrication Validation
Plan is completed satisfactorily, NRC concluded that CPC will be
able to verify that the MSBs will perform as designed.
b.
Exit Interview {30703)
The inspectors met with the licensee representatives denoted in
paragraph 1 during the inspection period and at the conclusion of
20
..
the inspection on August 19, 1994.
The inspectors summarized the
scope and results of the inspection and discussed the likely
content of this inspection report.* The licensee acknowledged the
information and did not indicate that any of the informatiori
disclosed. during the inspection could be considered proprietary in
nature.
21