ML18065A946
| ML18065A946 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/30/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18065A944 | List: |
| References | |
| 50-255-96-09, 50-255-96-9, NUDOCS 9610070324 | |
| Download: ML18065A946 (8) | |
See also: IR 05000255/1996009
Text
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Docket:
License:
Report:
Licensee:
Facility:
Location:
. Dates:
Inspector:'.*
U.S. NUCLEAR REGULATORY COMMISSION
. ** . REGION II I .
50-255
50-255/96009(DRS)
Consumers Power Co~pany
212 West Michigan Avenue
Jackson, MI
49201
Palisades Nuclear Generating Plant.
27780 Blue. Star Memori~l* Highway
Covert, MI
49043-9530
. August 13 through *.September 12 ~ 1996
P. louden; Senior Radiatiori.Spe~ialist *
Accompanying Staff:
D. Hart, Radiation Specialist
. Approved by:
T. Kozak, Acting Chief
Pl~nt Support Branch 2
9610070324 960930
ADOCK 05000255
G
EXECUTIVE SUMMARY
Palisades Nuclear Generating Plant *
NRC Inspection Report 50-255/96009
This report discusses the NRC review of circumstances surrounding the licensee
identified problem involving the alarm setpoint for the control room heating,
ventilation, and air-conditioning (HVAC) system continuous air monitor (CAM).
The revie_w concluded that the alarm setpoint had been nonconservatively
established since the installation of the continuous air monitor in 1988.
The
duration of this problem reflected a failure to institute appropriate design
control methods to ensure that the design basis for the system was met.
No
operability concerns were identified with the current control room HVAC CAM
configuration.
The inspector additionally identifi-ed a problem regarding the
training and qualifications of personnel performing engineering analyses.
One
engineering analysis reviewed was not completed in accordance with station
procedures due in part to the fact that the personnel involved with the
analysis had not been trained on the procedure used.
/
REPORT DETAILS
R2
Status of Radiological Protection and Chemistry Controls Facilities and
Equipment
R2.l Control Room Heating, Ventilation. and Air-Conditioning CHVAC) System
Continuous Air Monitor Alarm Setpoint
a. Inspection Scope (84750)
The inspector reviewed the circumstances surrounding a licensee
identified problem regarding the nonconservative alarm setpoint for the
control room HVAC continuous air monitor (CAM).
b. Observations and*Findings
On July 30, 1996, during the preparation of an engineering analysis for
control room habitability, a Nuclear Fuels engineer identified an error
in the alarm setpoint calculation for the control room HVAC CAM.
The
error was a factor of 60 higher than required. This problem was
immediately discussed with Radiological Services staff. The licensee
notified the NRC pursuant to 10 CFR 50.72(b)(l)(ii)(B) for plant
operations outside the design basis and, subsequently reporte*d the
problem in Licensee Event Report 96-011.
The control room HVAC.was
placed into emergency mode until the proper alarm setpoints could be
established. Rather than adjust the setpoints on the in-place CAM, a
new, state-of-the-art monitor was placed in service.
The system was
subsequently declared operable about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the discovery of the
problem.
-
The purpose of the CAM is to alert operators in the control room to
manually isolate the control room HVAC system during certain accident
scenarios. The control room HVAC system is automatically actuated ~nly
when Containment High Pressure (CHP) or Containment High Radiation (CHR)
indications are received in the control room.
For accident scenarios
during which a CHP/CHR signal is not received, the control room HVAC CAM
becomes the indicator to the control room operators that high airborne
radioactivity is present and prompts a manual isolation of the HVAC
system.
- *
The licensee initiated a root cause investigation into the matter and
determined that the condition had exiSted s i nee the CAM was* i nsta 11 ed on
the control room HVAC system in 1988.
The licensee determined that the
root cause of the setpoint error was that a standard equation was used to
calculate the setpoint threshold for partic_ul ate sampling_ over a sixty
minute timeframe rather than for noble gas sampling of a set volume at-
any instant. *At the time the original CAM was installed, the licensee
planned to evaluate the feasibility of establishing an automatic
actuation feature for the HVAC system in the event of a CAM alarm.
This
issue was deferred with no clear resolution.
The setpoint calculation
went without review, in part, because the original CAM was not entered
3
into the plant's tracking system for temporary modifications until 1994.
It remained a temporary modification until the discovery of the alarm
setpoint problem.
During.that time, field reviews were performed o~the
CAM's operability; however; a full evaluation of the appropriate sampling
and setpoint calculation methodology was not performed.
The new monitor.
is currently being tracked as a temporary .modification pending the
completion of the installation of two CAMs further up the ventilation
stream prior to the upcoming Fall 1996 refueling outage.
During a.
management review board meeting conducted on August 13, 1996, station
management discussed the feasibility of adding an automatic actuation
feature to the system.
It was determined at that meeting that the
automatic actuation feature would be evaluated by plant engineering and
operations.
The currently installed monitors were verified by the
inspector to be in proper calibration and.alarm setpoints were
established for the appropriate radioi~otopes.
- Since the alarm setpoint was set so high above the calculated threshbld
for noble gas activity, during an accident where a CHP/CHR signal was not
received, the control room operators could have received doses in excess
of the.limits defined in 10 CFR~50, Appendix A, General Design Criterion (GDC) 19.
This failure to.ensure GDC 19 limits would be maintained for
~
all accident scenari6~ is inconsistent with the design basis for the . *
control room HVAC system as described in the Final Safety Analysis Report
.Chapter 9.8.1.4. This is considered a violation of 10 CFR 50, Append1x
'B, Criterion III, "Design Control", for failure to adequately ensur*e that
measures are established to assure that design bases, as defined in 10*
CFR 50.2, are correctly translat~d into specifications~ drawings,
c. Conclusion
'
.
A review of the circumstances surrounding the. discovery of the control
room HVAC CAM alarm setpoint being nonconservative identified a failure
on the part of the licensee t6 adequately provide controls to ensur~ that*
calculations and monitoring parameters met design bases.
E3 ** * Engineering .Procedures and Documentation
a. Inspection Scope
As part of the review of the control room HVAC CAM alarm se.tpoint problem
(Section R2.l), the i~spector reviewed* Engineering Analy~is (EA)96-004,
"Response to C-PAL-96-0074A; Regarding Alarm Setpoint for High Range*
Noble Gas Mon it or at Pali sades & BRP.", for techn i ea 1 adequacy and
compliance with established licensee procedures;
b .. Q
.. bServatfo11* and .Findings ...
. The inspector reviewed EA 96-004 performed in May 199.6 by the. Chemical
.and Radiological Services (C.RS) department to determine if setpoints for.*
the high range noble gas monitor were conservative based on the
implementation of EPA-400, "Manual of Protective Action Guides and
4
Protective Actions for Nuclear Incidents".
The analysis concluded that
the current setpoint of 20 mrem/hr for the high range noble gas monitor
was appropriately conservative.
Howeverj during the technical revi~w of
EA 96-004, the inspector noted that two blocks on the cover sheet for the,
EA were not initialed as required by administrative procedure, 9.11,
Revision 8, "Engineering Analysis".
The specific blocks were:
The "Initiator Approved By" ,block, which was to be initialed by a
supervisor indicating the initiator is technically qualified to
perform the EA, and
The "Reviewer Approved By" block, which was to be initialed by a
supervisor indicating that the reviewer assigned was technically
qualified to review the EA.
The inspector identified the discrepancy to the li~ensee who initiated a
condition report (C-PAL-96-0984) to review the matter.
Immediate review
of the problem by the licensee revealed that the C&RS staff performing
the EA had not been trained on the use of administrative procedure 9.11.
The licensee was conducting further reviews of the issue at the
conclusion of the inspection.
The failure to ensure that qualified
individuals prepare and review EAs is considered a violation 'of 10 CFR
50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings~.
However, this matter is regarded a~ of minor significante and is being
treated as a Non-Cited Violation, consistent withrSection IV of the
Enforcement Policy. (NCV No. 50-255/96009-02)
c. Conclusion
No problems were noted with the technical content of EA 96-004.
Howeve~~
, a minor Violation for failure to follow EA procedure 9.11 to ensure that
, qualified individuals prepared ~nd reviewed EA 96-004 was identified by
the-inspector.
Xl
Exit Meeting Summary
, The inspector presented th~ inspection results to members of licensee
-
management during an interim exit meeting on August 28, 1996, and by
phone on September 12, 1996. 'The licensee acknowledged the findings
presented.
The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary.
No proprietary
information was identified.
5
PARTIAL ,LIST OF PERSONS CONTACTED
Licensee
T. Palmisano, Plant General Manager
D. Malone, Chemical & Radiological Services Manager
B. Gerling, Design Engineering Deputy Manager
. T. Berdine, Licensing Manager
B. Vincent, Licensing Supervisor
J. Beer, Health Physics Support Supervisor
T. Neal, Environmental Services Supervisor
T. Duffy,* Nuclear Fuels Supervisor
R. Mccaleb, Nuclear Performance Assessment Supervisor
D. Watkins, Nuclear Performance Assessment Engineer
T. Meyers, Nuclear Fuels Engineer
K. Schneider, Chemica1 and Radiological Services Training Facilitator
C. Mathews, Licensing Engineer
M. Parker, Senior Resident Inspector, Palisades*
W. Kropp, Chief, Division .of Reactor Projects Branch 3
Inspection Procedure Used
IP 84750, "Radioactive Waste Treatment, and Effluent and Environmental
Monitoring"
50-255/9~009-0l
50-255/960,09-02
50-255/96009-02
List of Items Opened
Violation
Failure to ensure proper design control was
established for the control room heating,
ventilation, and air-conditioning system as
required by 10 CFR 50, Appendix B, Criterion
III. Specifically, to ensure that design
bases were met in accordance with 10 CFR 50,
Appendix A, General Design Criteria 19.
Failure to follow procedures as required by 10
CFR ~O~ Appendix B, Criterion V.
List of Items Closed
Failure to follow procedures as required
by 10 CFR 50, Appendix B, Criterion V.
6
LISTING OF DOCUMENTS REVIEWED
Final Safety Analysis Report (FSAR) Chapter 9
FSAR Chapter 14
Palisades Condition Report C-PAL-96-0840
Consumers Power Memorandum "Site Emergency Plan Related Effluent Monitor
Setpoint Changes" dated 6/28/85 by R. Christie
- USNRC Safety Review Plan 6.4
.Licensee Event Report '(LER)88-013 Revisions 0, 1, 2, and 3, "Inoperable
Control Room Ventilation System"
LER 96-011 "Control Room Continuous Air Monitor Alarm Setpoint Improperly
Established"
Palisades Nuclear Plant Technical Specification Surveillance Procedure Number
RR-9K, Revision 3 dated 7/11/95
Palisades Nuclear Plant Technical Specification Surveillance Procedure Number
RR-848, Revision 3 dated 5/4/95
Palisades Nuclear Plant Technical Specification Surveillance* Procedure Number
RR~84C, Revision 2 dated 6/1/95
Temporary Modification 96-042, "Installation of temporary air monitor .(AMS-4)
in contro 1 room vi e*wi ng ga 11 ery", ~ated 7 /30/96
Temporary Modification 94-048, "AMS-3 air monitor in control room viewing.
gallery", dated 5/4/94
Engineering Analysis MRO 96-001, "S.tudy Comparing Eberline Engineering
Document 12000-A67 and Data Derived Using Plant Specific Noble Gas Isotopes to
Allow Efficiency Determtnation ori Noble Gas Head Using a Solid Source"~ dated
5/30/96.
Engineering Analysis96-004, "Response to C-PAL-96-0074A; Regarding Alar~
Setpoint for High Range Noble Gas Monitor at Palisades & BRP"
Palisades Procedure HP 9.77 Revision 7, "Operation and Calibration of the
Eberline Model AMS-4"
Palisades Procedure HP 9.43 Revision_6, "Operation and calibration of the
Eberline-Model AMS-3/3A"
7
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