ML18064A836
| ML18064A836 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/27/1995 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18064A834 | List: |
| References | |
| 50-255-95-07, 50-255-95-7, NUDOCS 9507070032 | |
| Download: ML18064A836 (20) | |
See also: IR 05000255/1995007
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I I I
Report No. 50-255/95007(DRP)
Docket No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Facility
Inspection At:
Palisades Site, Covert, Michigan
Inspection Conducted: April 13 through May 27, 1995
Inspectors:
M. E. Parker
J. Gadzala
D. G. Passehl
J. Foster
W.~K~\\~
- Approved By:
Reactor Projects Section 2A
Inspection Summary
S. Orth
R. M. Lerch
Inspection from April 13 through May 27. 1995 <Report No. 50-255/95007CDRP))
Areas Inspected: Routine unannounced safety inspection by resident and
regional inspectors of personnel errors, current material condition, onsite
event followup, maintenance activities, surveillance activities, engineering,
emergency preparedness, past emergency actuations, emergency plan and
procedures, emergency response facilities, organization, training,
- communications, chemistry confirmation measurements, chemistry quality
control, REMP, water chemistry control, maintenance self assessments,
chemistry and REMP audits, emergency preparedness audits, outage schedule,
action on previous inspection findings, and LER followup.
Results:
Of the 23 areas inspection, one violation and two unresolved items
were identified. The violation pertained to ineffective corrective action
(paragraph 5.2). The unresolved items pertained to cooling down the
pressurizer (paragraph I.I.I) and technical basis for extending of standard
expiration dates (paragraph 4.2.2). The following is an assessment of
performance during this inspection period:
Operations
On May 22, the reactor was manually scrammed from about 45 percent power
following sequential loss of both main feed pumps.
The resident inspector was
in the control room at the time of this event and observed good performance by
operators during the ensuing response.
Particularly noteworthy was the
9507070032 950627
ADOCK 05000255
G
-*
effective oversight provided by the shift supervisor, good communications
among operators, and periodic status updates to assist in event coordination.
However, a series of personnel errors occurred during the early stages of the
refueling outage. Although each event individually was of minimal safety
significance, collectively the events indicate a weakness in the process for
controlling plant activities in the areas of communications and attention to
detail on the part of plant personnel.
The licensee's overall performance in this area was satisfactory.
Maintenance
Miscommunication between operations and maintenance occurred when only a
partial tagout was desired, and a full tagout was issued. Control,
coordination, and engineering support of a main feed pump test was very good.
Although an extensive pre-job brief for a overspeed test was provided to
involved personnel, a voluminous amount of routine information concerning the
test was also promulgated. This tended to dilute the emphasis on precautions,
limitations, and key points and thereby reduced the effectiveness of the
brief.
The licensee's overall performance in this area was considered good.
Engineering
An assessment of the GL 89-10 motor operated valve program indicated that
management oversight of the program had improved significantly. Program
documentation was acceptable.
Plant Support
The overall status of the*emergency preparedness program was very good.
Response facilities were in a state of operational readiness, and the
Technical Support Center was being remodeled to improve its effectiveness.
Audits.and surveillances of the program were very good and satisfied
regulatory requirements.
The EP organization was adequately staffed.
Emergency communications capability was adequate.
However, EP training
modules needed updating.
The licensee demonstrated excellent performance in
the NRC radiological and nonradiological confirmatory measurements program.
Excellent primary and secondary systems water quality continued to be
maintained.
The trending of radiochemistry data to monitor reactor fuel
performance was very good.
Radiological and nonradiological measurements and
laboratory quality control continued to be very good.
The licensee's overall performance in this area was considered good *
2
Safety Assessment and Quality Verification
In some instances, the maintenance self assessments appeared to be self
critical and identified issues that needed improvement.
However, there were
some assessment that did not assess but provided status or verification that
activities were in compliance.
Overall, the licensee corrected chemistry audit findings in a reasonable time.
However, the inspector's review of Nuclear Performance Assessment Department
{NPAD) audits in the REMP area, QT-91-06 and PT-92-07 {1991 and 1992,
respectively) identified identical deficiencies that were identified by the
inspectors with the sampling techniques for a particulate air filter in a very
turbulent manner .. The deficiencies identified in the 1991 and 1992 NPAD
audits were not adequately corrected.
The audits and surveillances of the emergency preparedness program conducted
between 1993 and 1995 of the EP program satisfie~ the* requirements of 10 CFR
50.54{t) with respect to the scope.
The overall quality of the audits
reviewed was very good.
An independent safety review of the 1995 outage schedule conducted by the lead
Operations Assessor in the Nuclear Performance Assessment Department {NPAD)
with assistance from an outside contractor was thorough and comprehensive.
The licensee's performance in this area was considered satisfactory *
3
1.0
DETAILS
Operations (7I707, 7I750, 93702}
The plant operated at full power until May 22 when the reactor was
.
manually scrammed from 88 percent power following the loss of both main
feed pumps.
The plant then entered a refueling outage that was
scheduled to start May 28, I995.
I.I
Personnel Errors
A series of personnel errors occurred during the initial phase of the
refueling outage. These errors led to:
excessive cooldown of the pressurizer vapor space
inadvertent sluicing of two boric acid tanks
securing auxiliary feedwater flow while adding hydrazine
- .
steam generators being inadvertently filled solid
Although individually each error was of minimal safety significance,
collectively these errors indicated a weakness in the process for
controlling plant activities and inattention on the part of plant
personnel.
Pl~nt personnel identified each of these events and
corrective actions were initiated. Management classified these errors
as precursors and initiated action to collectively address these errors.
I.I.I Pressurizer Vapor Space Cooldown
The pressurizer vapor space indicated a cooldown from 32I°F to 2II°F
over a four minute period. Pressurizer liquid temperature remained at
ab~ut 2I0°F during this period with primary pressure at 250 psia.
Operators were performin*g procedure *SOP 1, "Primary Coolant System," to
fill the pressurizer solid, degas, and then perform a pressurizer
cooldown.
When the pressurizer was believed solid, operators initiated
a pressurizer cooldown.
Over the next four hours, pressurizer liquid
temperature was lowered from 400°F to 230°F.
However, pressurizer vapor
temperature had. only dropped to 335°F. This indicated that a*
noncondensible gas bubble existed at the top of the pressurizer. At
this. point, operators had Chemistry reinitiation degassing of the
pressurizer.
Resumpt.ion of degas vented off the hot (321°F). gas bubble, replacing the
gas with cooler (211°F} liquid. The rising liquid enveloped the vapor
space temperature detector, which then indicated the rapid temperature
drop. This issue remains unresolved pending further review by .the NRC
and licensee (255/95007-0I}
4
1.1.2 Other Personnel Errors
Later, during motor operated valve testing, two series valves were left
open simultaneously. This allowed water to sluice from a full boric
acid tank and equalize with another tank filled 20 percent with 3000 ppm
The valves were intended to be opened simultaneously, but
only for a very brief period. However, testing activities continued
into a second shift, and this aspect of the information was not
effectively communicated.
Plant management suspended motor operated
valve testing pending evaluation of this event.
In preparing to add hydrazine to the steam generators, chemistry
technicians lined up injection with the P-8A auxiliary feedwater pump.
However, operators had shifted to the P-8C auxiliary feedwater pump.
Consequently, the hydrazine was not injected. This error was identified
when subsequent sampling of steam generators revealed a lack of
hydrazine.
A steam generator filled solid following primary plant cooldown due to
water from an operating condensate pump leaking past the closed 68
feedwater heater outlet valve. Operators had previously secured
auxiliary feedwater pumps and secured from close monitoring of steam
generator levels. The full generators were discovered by an oncoming.
operator during shift turnover reviews.
1.2
Current Material Condition
With minor exceptions, the material condition of the plant was
con*sidered satisfactory.
Although primary coolant pump {PCP) seals continued to operate within
acceptable flow and pressure limits, some seal degradation was evident
in varying degrees on all four PCPs.
The greatest challenge to plant
-
operators has been controlling plant evolutions to protect the seals on
pump P-508.
Plant engineers have provided good support to operators in
planning and in conducting evolutions that could have affected the PCP
seals. The seals on at least three of the four PCPs were scheduled to
be replaced during the 1995 refueling outage.
- 1.3
- onsite Event Followup
On May 22, the reactor was manually scrammed from 88 percent power
following the loss of both main feed pumps.
Reactor power had initially*
been* at 88 percent when the A feed pump tripped. Reactor power was *
reduced to about 45 percent while operators attempted to stabilize steam
generator levels with the remaining feed pump.
Shortly thereafter, the
- B feed pump tripped and operators appropriately initiated a manual reactor scram.
Main feed pump A vibration had increased noticeably during the previous
night but had subsequently stabilized and was being monitored by the
engineering staff. Plant management reviewed the vibration analysis and
5
decided to reduce reactor power and remove the pump from service.
However, mechanical fai1ure of an auxiliary shaft in the A main feed
pump, believed to be associated with the high vibration, caused the pump
to trip on overspeed before this action was implemented.
Operators responded promptly. to the event and were initially successful
in recovering steam generator levels with the remaining pump.
However,
the B steam generator was overfed, causing the feed regulating valve to
automatically shut as level rose past 84 percent. According to the
plant's engineering analysis, the resultant drop in loading on the feed
pump caused pump speed to briefly increase.
Because the pump had
initially been operating at maximum limit on the governor, the increase
in speed was sufficient to react the overspeed trip setpoint and trip
the pump.
Subsequent testing of the B pump identified that the
overspeed trip setpoint was only slightly below the value that had been
set at during the previous refueling outage.
About six minutes elapsed from the time the first feed pump tripped
until the second pump tripped. Operators were quick to recognize the
loss of the second feed pump and inunediately initiated a manual reactor scram. Appropriate emergency procedures were entered and methodically
performed.
The event was reported as required.
All systems operated as expected following the scram with the exception
of the rod 25 bottom light. Correct rod position was verified using
individual rod position indication. The unit was placed in hot
shutdown, and preparations were made for .early commencement of the
refueling outage that had ori.ginally been scheduled to start May 27.
The resident inspector was in the control room at the time of this event
and observed good performance by operators during the ensuing response.
- Particularly noteworthy was the effective oversight provided by the
shift supervisor, good communications among operators, and periodic
status updates to assist in event coordination.
2.0
Maintenance (62703, 61726)
2.1
Maintenance Activities
Pcirt~ons of the following maintenance activities were observed or
reviewed:
Work Orders 24414954 and 24510431, Perform Various Preventive
Maintenance Activities on Emergency Diesel Generator 1-2.
The inspector observed good management oversight of this activity.
WR 247594, Main Feed Pump Overspeed Test Post Maintenance Test
A special procedure was written to determine the overspeed trip setpoint
of this pump as part of the evaluation of the May 22 reactor scram .
6
Control and coordination of the test by the shift supervisor was very
good.
Extensive engineering support was also noted.
Procedures were
evident and in use at the test location.
Although an extensive prejob brief was provided to involved personnel, a
voluminous amount of routine information concerning the test was also
promulgated.
This tended to dilute the emphasis on precautions,
limitations and key points and thereby reduced the effectiveness of the
brief.
Work Order 24303851, Repair Waste Gas Compressor
A miscommunication between operations and maintenance personnel occurred
when only .a partial tagout was desired and a full tagout was issued.
Work Order 24300767, Perform Maintenance on P-858 Evaporator*
Recirculation Pump
A miscommunication between operations and maintenance personnel occurred
when tagging was released by maintenance personnel before all the work
was completed.
The licensee took aggressive corrective action in light
of previous tagging problems.-
Work Instruction Wl-l-FC-933-96-01, Plant Process Computer Upgrade
Project - Datalogger
A personnel error. occurred when a technician opened the wrong breaker
cubicle door._- A technician preparing to perform motor operated valve
testing opened the door of a breaker cubicle adjacent to the desired
breaker. This error was quickly caught by both the technician and
operators in the area.
No work was performed in the wrong cubicle.
Another personnel error occurred when a crane was moved in the turbine
building with the boom raised resulting in a collision between the boom
and an overhead support structure. Fortunately, only superficial damage
occurred. The cause was attributed to inattention on the part of the
crane operator.
2.2
Surveillance Activities
Portions of the following surveillances were observed with no problems
or concerns being identified:
Q0-15, Inservice Test Procedure - Component Cooling Water Pumps
Q0-5, Valve Test Procedure (Includes Containment Isolation Valves)
M0-29, Engineered Safety System Alignment
M0-33, Control Room Ventilation Emergency Operation.
7
3.0
Engineering (37700, 37551, 60846, 86700)
A September 1994 inspection of the Palisades GL 89-10 motor operated
valve (MOV) program identified numerous deficiencies and concluded that
plant management provided ineffective direction and oversight of the GL 89-10 program.
On May 3, 1995, the NRC was briefed on GL 89-10 program
status and subsequently performed a followup assessment.
This assessment indicated that management oversight of the program had
improved significantly. Additional resources devoted to the program,
such as augmented staffing and increased management attention, were
effective. The schedules for MOV activities and program closure were
well organized, and previously identified weaknesses were being
appropriately addressed.
Based on MOV testing planned during the 1995 refueling outage, the plant
appeared to be able to adequately validate design basis assumptions.
Other aspects of the program, such as the periodic verification of MOV
capability, also appeared to be acceptable.
A brief review of MOV program documents, test procedures, and the
torque/thrust calculations used to determine appropriate thrust windows
identified no concerns. Conservatism and proactiveness was noted in
many aspects, such as the application of pullout efficiency to the
opening and closing thrust calculations and the intent to measure torque
in every diagnostic test. However, this conservatism was not applied in
cases such as the assumption that load sensitive behavior was not
applicable *to the open stroke and in the use of flow cutoff thrust to
calculate valve factor.
Many of the calculational weaknesses noted
during the previous inspection had been addressed. Overall, the program
documentation was acceptable.
4.0
Plant Support
4.1 *Emergency Preparedness (82701)
The inspector reviewed an Unusual Event that was declared on
February 17, 1994, when a plant shutdown was required due to a
through-wall leak on a check valve; and an Unusual Event that was
declared on December 8, 1994, due to an auxiliary feedwater valve being
Reviewed records indicated that classifications and notifications had
been made properly and in a timely.manner.
Documentation packages for
each event were detailed, complete and technically correct.
4.1.1 Emergency Plan and Procedures
Discussion with plant personnel indicated many implementing procedures
were being reviewed and revised.
The inspector discussed acceptable
deviations to the Emergency Action Levels in NUREG-0654, including
deletion of the Technical Specification Shutdown Unusual Event.
8
Licensee personnel indi~ated that Emergency Plan changes to address
acceptable deviations would be forthcoming.
Potential revisions of the
Plan regarding dose assessment actions by Control Room personnel were
also discussed.
4.1.2 Emergency Response Facilities
Tours were conducted through the Control Room, Technical Support Center
(TSC), Operational Support Center (OSC), and Emergency Operations
Facility (EOF).
Each facility was well maintained and in an operational
state of readiness. Required, current copies of the Emergency Plan and
Emergency Plan Implementing Procedures and appropriate forms were
present in the facilities.
The TSC was in the process of being remodeled.
The new design removed
several barriers to internal facility communication. A copy of the
Emergency Plan was not available in the TSC, but there were no Emergency
Plan or procedural requirements to have the Plan available.
New offsite field monitoring team vehicles were inspected and found
operational.
Documents reviewed indicated that emergency equipment inventor1es and
maintenance were very good, with timely corrective actions taken where
deficiencies were identified.
4.1.3 Organization
Site duties were adequately shared between two Emergency Planners, who
reported to the Emergency Planning Administrator, who reported to the
Director of Nuclear Services, who reported to the Vice Prestdent,
Nuclear Operations.
The reporting chain for Emergency Preparedness did
not include the plant organization. Corporate office Emergency Planning
staff, including the Emergency Planning Administrator, was in the
process of being relocated to the site.
4.1.4 Training
Records indicated that drills and exercises were formally critiqued and
significant critique items selected for corrective action as
appropriate.
Three individuals with positions in the emergency response organization
were interviewed and found to be knowledgeable of the duties and
responsibilities of the positions.
Two individuals interviewed were
unable to discuss aspects of the NRC incident response program (see
Inspection Follow-up Item 50-255/94009-03 in Section 6.0 of this
report).
The inspector reviewed the "Emergency Employee Augmentation Listing" and
the training "Requirement Status" printout.
No Emergency Response
Organization (ERO) personnel were out of ~ualification; however, 16
9
individuals were identified as beyond the 12 month retraining period but
still within the 3 month allowable "grace period." Discussion indicated
these individuals were in various stages of requalification training.
The inspector attended emergency notification training for auxiliary
operations candidates. The instructor provided good examples and
responses to perceptive questions by the students.
Review indicated that some EP lesson plans had not been revised since
1991, and the most recent were dated 1993.
Lesson plans were scheduled
to be reviewed by the EP training instructor by the end of 1995,
beginning during the 1995 outage.
4.1.5 Communications
The primary offsite emergency communications method was by commercial
phone.
Also available was Consumers Power Centrex phone system, two
radiation monitoring team (RMT) cellular phones, FTS 2000 telephones and
the plant radio.
The plant radio system was capable of communicating
with the Sheriff's Department in Paw Paw, MI, Power Control in Jackson,
MI, and the State Police in South Haven, MI.
Communications diversity
was adequate.
4.2
Chemistry and Radiological Environmental Monitoring Programs (84750)
4.2.1 Chemistry Confirmatory Measurements
The licensee demonstrated excellent performance in the NRC rad;olog1ca1
and nonradiological confirmatory measurements program.
The inspectors
submitted nonradiological chemistry samples to the licensee, which were
analyzed by the licensee in the concentration ranges of typical plant
samples using routine methods and instruments.
The inspectors also
compared gamma isotopic measurements of primary cool ant (filter and*
filtrate), a liquid sample from a safety injection tank, and a prepared
particulate air filter sample on the licensee's three high purity
germanium detectors and on the NRC detector in the NRC Region III
laboratory.
The licensee achieved agreements in all compari~ons. Some minor biases
were observed in the radiological comparisons, but the biases were
conservative versus the NRC results. The licensee's radiochemist was
monitoring instrument performance well.
Laboratory practices and laboratory housekeeping were very good with
minor exceptions.
The inspectors found lighting in the PASS area to be
poor. This deficiency was quickly corrected. A lack of lighting could
lead to difficulties in obtaining a sample .
10
4.2.2 Chemistry Oyality Control
Chemistry quality control was very good, with the exception of control
of chemistry standards. All required comparison programs were properly
- implemented.
Some performance problems were noted in the
nonradiological program with a significant number of disagreements being
attributed to technician errors in preparing dilutions. The laboratory
supervisor was aware of the weakness and was taking measures to improve
performance.
Control charts for laboratory and inline chemistry instruments were
properly maintained. Additionally, post accident sampling system (PASS)
quality control was very good, and chemistry comparisons verified that
the PASS samples were representative of primary coolant.
Although overall analytical performance was excellent and no performance
problem was identified concerning the adequacy .of chemistry data, the
inspectors identified weaknesses in the control of nonradiological
chemistry standards.
The licensee allowed the expiration dates of
standards to be extended (indefinitely) beyond the manufacturer's
certified date or licensee's initially assigned expiration date.
No
technical basis for this extension was available. The following
problems were noted with the control of standards:
concerns were identified with the implementation of control of
standards
weaknesses in the supervisory approval and documentation
weaknesses in labelling
prepared reagents being assigned expiration dates beyond that of .
the parent standard/reagent
weaknesses in traceability to the parent standard/reagent.
The technical basis of the extension of expiration dates and the
implementation of this process remain unresolved pending additional
information and review (255/95007-02).
4.2.3 Radiological Environmental Monitoring Program CREMPl
Overall, oversight of contractor performance in the REMP was poor.
The
1992, 1993, and 1994 Annual Environmental Operating Reports indicated
that samples were collected and analyzed in accordance with the
licensee's Off-site Dose Calculation Manual (ODCM).
Samples which were
not obtained were documented in the report as required, but
documentation was poor in addressing reasons for the occurrences and
methods to prevent recurrence.
The report did not indicate any abnormal
radiological release to the environment .
11
The inspector identified poor sampling techniques in the routine air
sample collectfon. Although sampling equipment was in excellent
material condition, sample collection techniques were deficient. The
sample collector removed the particulate air filter in a very turbulent
manner which undermined the integrity of the sample, and the replacement
filter was incorrectly installed in the sample holder.
The labeling and
tracking of filters was also in need of improvement.
Following the
inspectors' observations, the licensee revised Health Physics Procedure
No. 10.10, "Palisades Radiological Environmental Program Sample
Collection and Shipment," to address the concerns by providing explicit
instruction for sample removal and replacement. Additionally, the
licensee's REMP coordinator committed to quarterly accompaniments with
the collector and review of all offsite sample collectors' techniques.
The inspector's review of Nuclear Performance Assessment Department
(NPAD} audits of this area *identified a concern. This is further
discussed in Section 5.2 of this report.
4.2.4 Water Chemistry Control Program
Primary and secondary water chemistry has been well maintained.
Steam
generator (SG) chemistry improved notably from the last inspection.
During the end of April 1995, a small condenser leak appeared to 'degrade
the SG chemistry minimally.
However, the intrusion has been well
tracked and has appeared to subside. During the upcoming refueling
outage, the licensee planned to inspect the condenser and to isolate any
identified leaks.
Prior to the occurrence of the condenser tube leak, steam generator
sodium, chloride, and sulfate levels averaged about 0.5 parts per
billion (ppb), 1.5 ppb, and 0.5 ppb, respectively.
Industry median
values for chloride and sulfate levels were 2 and 3 ppb, respectively.
The intrusion increased the chloride and sulfate levels to 2 and 1.5
ppb, respectively. The licensee monitored the chloride-to-sodium ratio
to ensure a neutral crevice pH.
Steam generator iron levels continued
to be very low (less than about 0.5 ppb).
5.0
Safety Assessment and Quality Verification
5.1
Maintenance Self Assessments
The inspectors reviewed the following recent self assessments performed
by the maintenance department:
- * * * *
Work Order Control Process--May 1995
Work Order Backlog--May 1995
Control Room Deficiency Management Plan--May 1995
Planning and Scheduling--January 1995
Assessment Report for "Review of PPAC Reports with Expired Grace
Dates"-March 1995
Assessment Report for "PPACs on Identical Equipment with Same
Activity But With Different Intervals"--March 1995
12
Assessment Report for "Switching and Tagging Order Status"-
February 1995
Assessment Report for "C-2A Rework"-February 1995
In some instances, the self assessments appeared to be self critical and
identified issues that needed improvement.
During this inspection, the
inspectors did not verify the effectiveness of the licensee's actions to
resolve identified issues.
However, there were some assessments that
did not assess but provided status oi verification that activities were
in compliance. Two assessment reports that pertained to the review of
PPACs with expired grace dates and to the switching and tagging order
status could have been more effective. The assessment of PPACs with
expired grace dates consisted of verifying that justification forms
existed and did not review the adequacy of the rescheduling
justifications. The other PPAC pertaining to switching and tagging
orders {STO) was an effort to document the status of open STOs and did
not address an assessment of the area.
5.2
Chemistry and REMP Audits
The inspectors reviewed audits performed in the chemistry and REMP
program areas. Audits were performed as required, and findings were
technically based and were in good detail. Overall, the audits focussed
on sample collection and laboratory performance, which were found to be
very good.
Discussions with the audit teams indicated that additional
emphasis would be placed on plant and systems water chemistry.
Overall, the licensee corrected chemistry findings in a reasonable time.
However, the inspector's review of Nuclear Performance Assessment
Department {NPAD) audits in the REMP area, QT-91-06 and PT-92-07 {1991
and 1992, respectively) identified identical deficiencies that were
identified by the inspectors during this inspection {see paragraph
4.2.3). The inspector identified that a sample collector removed a,
particulate air filter in a very turbulent manner.
A subsequent 1993
. NPAD audit did not identify any concerns with sampling; however, a
different sample collector was observed by the auditors.
The
deficiencies noted in the 1991 and 1992 audits were not adequately
corrected. The failure to correct the sampling deficiencies is
considered a violation of 10 CFR 50, Appendix B, Criterion XVI, which
states that measures be established to ensure that deficiencies are
promptly identified and corrected (50-255/95007-03(DRP).
5.3
Emergency Preparedness Audits
The inspectors reviewed audits and surveillances of the emergency
preparedness program. The audits and surveillances conducted between
1993 and 1995 of the EP program satisfied the requirements of 10 CFR
50.54(t) with respect to their scope.
An assessment of the
effectiveness of the licensee's interfaces with State and local
emergency response agencies was performed as a subsequent surveillance,
and had been made available to offsite officials. The overall quality
13
of the audits reviewed was very good.
Heavy emphasis was placed on
performance based auditor activities, such as observing drills and
exercises, or ongoing periodic equipment inventories and operability
tests. The audits and surveillances reviewed were:
Audit Report No. PA-95-01, dated March 31, 1995
Audit Report PA-94-01, dated March 7, 1994, and
Audit Report PA-93-21, dated November 3, 1993.
Surveillance NPAD-/P-94-057
5.4
Outage Schedule
Plant management discussed the results of an independent safety review
of the 1995 outage schedule. The review was conducted by the lead
Operations Assessor in the Nuclear Performance Assessment Department
{NPAD) with assistance from an outside contractor. The NPAD review of
the outage schedule was thorough and comprehensive. Overall, the review
found that the licensee had adequate controls in place to manage risk
during shutdown and low power operations.
Some minor items were
identified to management for followup.
6.0
Action on Previous Inspection Findings {92901, 92902, 92903, 92904)
CClosedl Violation 255/92015-la:
While removing the reactor vessel
head, the licensee failed to adhere to the requirements of procedure
RVG-M-2 "Removal Of Reactor Vessel Head" by not using a calibrated load
cell and by exceeding the prescribed procedural maximum allowable 1 ift
weight.
In response to this violation, the licensee performed a review of all
the reactor disassembly/reassembly permanent maintenance procedures.
Procedure RVG-M-2 "Removal Of Reactor Vessel Head" was revised to ensure
that operators used the correct type of load cell when lifting the
reactor vessel head and to ensure that the load cell was within was
within its calibration periodicity. Additionally, this procedure was
revised to contain specific hold points to verify that indicated loads
will not exceed those that are expected.
The inspectors reviewed and
were satisfied with the licensee's corrective actions.
(Closed} Violation 255/92015-lb: - While removing the upper guide
structure, the licensee failed to adhere to the requirements of
procedure RVI-M-1 "Removal and Storage of The Upper Guide Structure" by
not using a calibrated load cell and by exceeding the prescribed
procedural maximum allowable lift weight.
In response to this violation, the licensee performed a review of all
the reactor disassembly/reassembly permanent maintenance procedures.
Procedure RVI-M-1 "Removal and Storage Of The Upper Guide Structure" was
revised to ensure that operators used the correct type of load cell when
lifting the upper guide structure and to ensure that the load cell was
within its calibration periodicity. Additionally, this procedure was
14
revised to contain specific hold points to verify that indicated loads
will not exceed those that are expected.
The inspectors reviewed and
were satisfied with the licensee's corrective actions.
(Closed) Violation 255/92015-lc:
Power was lost to the "C" safeguards
bus causing a subsequent loss of shutdown cooling.
Corrective actions included conducting training that clarified licensee
management's expectations regarding the manipulation of plant equipment
by non-operations department personnel inside and outside of tagging
boundaries. Training was also conducted that defined the duties and
responsibilities of Auxiliary Operators while supporting other work
groups. Additional training on the breaker testing requirements
contained in Administrative Procedure 4.02 "Control of Equipment Status"
was also conducted. This training covered the importance of procedural
compliance and the Manual Transfer Trip feature of 2400/4160V bus feeder
breakers which causes them to trip when the breaker is placed in the
test position. Additionally, caution placards that alerted operators to
the Manual Transfer Trip feature of these breakers were relocated to
- readily visible places within the cubicles that housed these breakers.
The inspectors reviewed and were satisfied with the licensee's
corrective actions.
(Closed) Violation 255/92015-ld:
Inadvertent Engineered Safety
Actuation Caused By Inadequate Test Procedures .
In response to this violation, the licensee revised procedures to add
sufficient detail to ensure a proper connection between the Data
Acquisition System to the plant sequencers.
Labeling of the test plugs
on the plant sequencers was revised to be consistent with plant
drawings. Additionally, plant drawings were updated to identify all
wires in the test cables and their associated termination points in the
test cable plugs.
The inspectors were satisfied with the licensee's
corrective actions.
<Closed) Violation 255/92015-le:
Inadvertent Actuation Of left Channel
Normal Shutdown Sequencer During The Performance Of Special Test T-325
"Timing of Emergency Diesel Generator 1-1 Start Sequence.
In response to this violation, the licensee conducted training on
procedural compliance with all operating shifts. The individual
responsible for this violation was also administratively disciplined.
The inspectors reviewed and were satisfied with the licensee's
corrective actions.
(Closed) Violation 50-255/93016-05:
The maintenance procedure used to
verify that control rod rack extensions were properly uncoupled was
inadequate.
The licensee has since scheduled corrective actions for
this item .
15
CClosedl Violation 255!93020-03a:
Failure to develop procedures to
identify trends in radiochemistry to assure that reactor fuel was
performing properly.
The chemistry and engineering groups' fuel integrity tracking procedures
and assessments were very good.
The licensee completed a comprehensive
industry evaluation to ensure that proper radioisotopes were trended and
evaluated.
Revision I to procedure number CH I.IO, "Fuel Integrity
Monitoring," provided acceptable data collection and assessment
criteria. Additionally, the licensee provided the radiochemistry trends
to an industry contractor for review and assessments.
The licensee's
current estimate of I-3 leaking fuel rods appeared consistent with the
radiochemistry indicators.
{Closed) Unresolved Item 255/94008-01:
The licensee's program for
. performing containment closeout was not fully effective.
In response, the licensee agreed to respond in writing describing what
actions had been planned to ensure that future containment closeouts
will be more effective. The inspectors reviewed the licensee's response
dated September I9, 1994 and were satisfied with the proposed corrective
actions.
{Closed) Unresolved Item 255/94008-02:
RI-47, "Rod Withdrawal Prohibit
Interlock Matrix Check" Rev.6 .
Immediate corrective actions included reviewing remaining test
procedures to verify their performance in the proper mode and to ensure
that no unanticipated mode changes were directed. The importance of
pre-job briefings and questioning attitudes was emphasized to all plant
personnel.
Permanent corrective actions included incorporating "lessons.
learned" from this evolution into the licensee's training program.
Procedures RI-47 and SOP-6 were revised to clarify the definition o.f a
control rod withdrawal and to specify the required plant conditions for
control rod withdrawal. Additionally, AP I0.4I "Procedure Initiation
and Revision" was revised to encourage the consideration of multiple
user reviews when a proposed procedure involves more than one department
or discipline. The inspectors were satisfied with the licensee's
proposed corrective actions.
(Closed) Violation 255/94008-3:
The spent fuel crane unexpectedly
stopped during preoperational testing for the dry fuel storage project.
In response, the licensee implemented a design change which corrected
the miswiring in the relay control panel.
The new l-3 control box
switches were restored to their proper configuration and function.
The
design change was verified with detailed test instructions which fully
tested the bypass/interlock functions of the radio control box switches.
The licensee also reviewed other post modification tests from
modifications in the last two years where reliance was placed on
existing maintenance work instructions/procedures or Technical
Specification procedures. This review determined that these procedures
I6
contained adequate post modification testing and that this violation did
not constitute a generic problem. Additionally, a "lessons learned"
.
letter concerning the use of existing maintenance procedures for post
modification testing was issued to the licensee's engineering
department.
(Closed) Inspection Follow-up Item 255/94014-50:
Fuel oil transfer ~ump
surveillance procedure M0-7C did not verify pump operability because it
lacked quantitative acceptance criteria.
As corrective action, Surveillance Test Procedure M0-7C, "Fuel Oil
Transfer Pumps," was revised to include discharge pressure acceptance
criteria. The basis document for M0-7C was revised to explain transfer
pump testing and how the test demonstrates transfer pump operability.
Surveillance Test Procedures M0-7A-1(2), Attachment 6, "P-lSA(B) Fuel
Oil Transfer Pump Test," was revised to have the fuel oil transfer pumps
volumetric flow rate checked on a quarterly period to verify that the
pumps can meet minimum flow requirements. Vibration readings are also
taken every quarter.
(Open) Inspection Follow-up Item 50-255/94009-03: Training for key
emergency response personnel did not cover the incident response program
of the NRC or other federal agencies. A letter was issued by the
Emergency Planning Administrator to Site Emergency Directors and
Emergency Operations Facility (EOF) Directors on May 9, 1994 providing
essentials of the NRC incident response program.
An attachment was also
added to Lesson Plan N00336-4, "Emergency Preparedness Orientation", to
provide basic training on NRC incident response, but this training had
not been presented.
Two individuals interviewed were unable to discuss
the NRC incident response program or the Federal Radiological Monitoring
and Assessment Center (FRMAC).
This item will remain open.
(Closed) Inspection Follow-up Item 255/95004-03: control of packing.
replacements on air operated valves. The licensee acknowledged that
vendor specific packing configurations had not been evaluated for other
valve styles, however this type assessment would be part of the AOV
program under development.
The performance of valves after packing
replacement was confirmed by post maintenance testing that was assigned
and reviewed by engineers administering the inservice testing program as
part of the work order process.
7.0
Licensee Event Report CLER) Follow-up (40500, 92700, 81502)
Through direct observations, discussions with licensee personnel, and
review of records, the following event report was reviewed to determine
that reportability requirements were fulfilled, and that corrective.
action to prevent recurrence had been or would be accomplished:
(Closed) LER (255/91014-03): Several safety related circuits were
routed with opposite channel cables. The licensee identified the cable
routing errors during the Palisade's Configuration Control Project (CCP)
reviews. This event involved 40 circuits which were believed to be
17
safety related and routed with opposite channel circuits. A number of
these circuits were later identified as nonsafety related. The LER
identified 15 safety related wiring schemes that did not meet Palisade's
channel separation requirements.
Five of the separation errors were
corrected and the licensee concluded the remaining 10 schemes did not
create an unreviewed safety question.
Palisade's FSAR stated that the
plant was not designed to IEEE 384, "Criteria for Independence of Class
IE Equipment and Circuits." In addition, the FSAR stated that, "A few
circuits have been discovered that are not separated as described below.
When deviations from separation requirements are identified they are
evaluated for acceptability as-is or rerouted." The inspectors reviewed
the licensee's safety evaluation and engineering analysis for each of
the identified cable separation schemes.
The safety evaluations and
engineering analyses were satisfactorily performed.
The inspectors
concluded that the current cable routings did not create an unreviewed
safety question.
From the engineering reviews, the inspectors
determined that the identified schemes were not routed with any
redundant circuits.
{Closed) LER (255/93013): Loss of Emergency Onsite AC Power Due To Both
Emergency Diesel Generators Being Simultaneously Inoperable
Corrective action for this LER included submitting a revision to the
electrical section of Palisades Technical Specifications which will
emulate the NUREG 1432 "Standard Technical Specifications for CE Plants"
electrical section. This revision will be incorporated in the
conversion to Standard Technical Specifications scheduled for submittal
in April 1996.
(Closed) LER (255/94013}: Unsupported Reactor Coolant Pump Instrument
Tubing .Identified As Being Outside the Plant Design Basis Due To Lack of
Supports:
On April 27, 1994, a 30~foot section of %-inch Reactor Coolant Pump
{RCP} instrumentation tubing was found without supports. The
unsupported section did not meet the stress analysis requirements
outlined in instrument tubing Specification M-195{Q} and was therefore
outside of its design basis. The discovery prompted further walkdown
inspections revealing that all 4 RCPs had instrument tubing support
deficiencies of a similar nature. These sections of tubing were
declared inoperable and were subsequently analyzed and repaired prior to
startup from the 1994 forced outage.
The inspectors reviewed the root cause analysis and corrective actions
performed due to this LER.
The probable root cause of these tubing.
support deficiencies included a combination of desi9n issues {lack of
isometrics for these installations}, maintenance issues {improper tubing
support reassembly following equipment maintenance}, and programmatic
issues {inadequate inspection program).
18
In response, a walkdown by plant personnel of the majority of small bore
piping and instrument tubing in safety related systems was organized and
completed.
Deficient supports were repaired prior to plant heatup from
the 94 forced outage and the remaining deficiencies were scheduled for
repair during the 95 REFOUT.
Additionally, Palisades has generated
system walkdown guidelines and implemented further controls on
maintenance activities to provide direction with respect to hanger and
support issues. Furthermore, to consolidate the various hanger and
support programs and processes a technical point of contact for hanger
discrepancies has been established. These actions were reviewed by the
NRC and found acceptable.
CClosedl LER C255/94016l:
The licensee revised its boron analysis
procedure to implement gravimetric methods.
The revised analytical
method appeared acceptable, and the event review appeared very good.
Subsequently, the licensee estimated experimental errors from the
previous, volumetric method.
The resultant calculation indicated that
the boric acid storage tanks may have been below the Technical
Specification {TS) required 6.25 weight percent boron {B) concentration
{1.e. 10,900 parts per million {ppm) 8). The licensee calculated *
concentrations of 10677 ppm B {tank A) and 10534 ppm B {tank B) for
March 18, 1991, and 10760 ppm B {tank B) for November 29,
1993~
Although the error corrected concentrations appeared to have been
outside of TS limits, the values were initially determined to be within
the TS requirements using acceptable analytical techniques and equipment
and were within an acceptable margin of sampling and analytical error.
Boron concentrations were reviewed for the current cycle, with no
problems identified.
8.0
Exit Interview {71707)
The inspectors met with licensee representatives denoted in section 1 at
the conclusion of the inspection on May 26.
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 information disclosed during the
inspection was proprietary.
9.0
Persons Contacted
R. A. Fenech, Vice President, Nuclear Operations
T. J. Palmisano, Plant General Manager
K. P. Powers, Engineering and Modifications Manager
R. M. Swanson, Director, NPAD
D. W. Rogers, Operations Manager
D .. P. Fadel, Engineering Programs Manager
J. P. Pomaranski, Deputy Maintenance Manager
.
H. L. Linsinbigler, Project Management and Modifications Manager
S. Y. Wawro, Planning Manager
K. M. Haas, Safety & Licensing Director
R. B. Kasper, Maintenance Manager
R. C. Miller, Deputy Engineering and Modifications Manager
19
C. R. Ritt, Administrative Manager
R. M. Rice, System Engineering Manager
M. P. Knopp, Chemistry Superintendent
D. J. Malone, Radiological Services Manager
D. G. Malone, Shift Operations Superintendent
R. A. Vincent, Licensing Administrator
D. J. Vanderwalle, Plant Support Engineering Manager
- Denotes those attending the exit interview conducted on May 26, 1995.
The inspectors also had discussions with other licensee employees,
including members of the technical and engineering staffs, reactor
and auxiliary operators, and shift engineers .
20