ML18065B168
| ML18065B168 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18065B166 | List: |
| References | |
| 50-255-97-18, NUDOCS 9803030376 | |
| Download: ML18065B168 (21) | |
See also: IR 05000255/1997018
Text
U.S. NUCLEAR REGULATORY COMMISSION
Docket No:
License No:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9803030376 980226
ADOCK 05000255
G
REGION Ill
50-255
50-255/9701 B(DRP)
Consumers Power Company
212 West Michigan Avenue
Jackson, Ml 49201
Palisades Nuclear Generating Plant
27780 Blue Star Memorial Highway
Covert, Ml 49043-9530
December 6, 1997, through January 27, 1998_
P. Prescott, Resident Inspector .
E. Schweibinz, Regional Inspector
Bruce L. Burgess, Chief
Reactor Projects Branch 6
EXECUTIVE SUMMARY
Palisades Nuclear Generating Plant
NRC Inspection Report No. 50-255/97018
This inspection reviewed aspects of licensee operations, maintenance, engineering and plant
support. The report covers a seven-week period of resident inspection,
Operations
The operators responded appropriatelyJo a loss of component cooling water event that
occurred on January 1, 1998. The licensee established an incident response team (IRT)
to investigate the circumstances surrounding the event, and the inspectors concluded
that the IRT's findings and proposed corrective actions were thorough. However, the
inspectors identified several IRT weaknesses, most significantly, the team's lack of
understanding of Generic Letter 91-18 regarding degraded conditions. The inspectors
discussed the weaknesses with licensee management and concluded that the corrective
actions taken or planned were adequate (Section 01.2).
Following the discovery of a mispositioned valve at a nitrogen station, the li.censee
instituted an equipment status control record to enhance the operations department's
control of equipment. To date, no discrepancies have been identified (Section 01.3).
Maintenance
The inspectors concludE;id that the spent fuel pool maintenance activity to repair body to
bonnetleaks on two valves, MV-SFP131 and MV-SFP132, was well planned and
executed. However, the inspectors noted one deficiency in that the nuts and bolts on the
valves were heat treated steel instead of stainless steel. An unresolved item was opened
pending a review of the licensee's evaluation of the nuts and bolts (Section M1 .2).
Engineering
During follow up to a March 1997 failure of CV-3018 to reposition, the inspectors
concluded that the corrective action for air line filter placement for pressure control valves
(PCVs) was inadequate in that the licensee fail~d to correct a previously identified
condition adverse to quality. The inspectors further concluded that placement of low
point drains in the air lines leading to the PCVs was inadequate. The low point drain
problem and the lack of corrective action for the air filter placement problem led to failure
- of CV-3018's air regulator. A violation of NRC requirements was identified (Section E1 .1).
The inspectors concluded that the system engineer had adequately prepared to perform
leak checks on the radwaste evaporator component cooling water supply and return
valves. However, the inspectors noted that the system engineer did not communicate to
the control room supervisor all of the activities performed in preparation of valve testing
(Section E1 .2).
2
Three 10 CFR 50, Appendix R, issues were of concern because of the safety significance
associated with plant equipment con*figuring that did not meet 10 CFR Part 50,
Appendix R, safe shutdown requirements for a design basis fire. These issues would
normally be designated as a Severity Level Ill problem in accordance with the NRC's
- NUREG-1600, "General Statement of Policy and Procedures for NRC Enforcement
Actions," (Enforcement Policy). However, enforcement discretion will be used in
accordanc.e with Section Vll.8.3, "Violations Involving Old Design Issues," of the
Enforcement Policy and a Notice of Violation will not be issued. The decision to apply
enforcement discretion was based on consideration of the following: 1) significant NRC
enforcement action (EA 96-131) was taken against the Consumers Energy Company for
several examples of a failure to take prompt corrective actions related to Appendix R
deficiencies. Palisades identified the issues detailed above and promptly notified the
NRC; 2) corrective actions were immediate and encompassed the root causes for these
issues; 3) some of the issues were related to activities that were in progress before the
enforcement action was issued; 4) the issues would not be classified at a severity level
higher than Severity Level Ill; and 5) Consumers Energy Company met with the NRC to
explain their efforts to resolve these issues, which were outlined in their reply dated
September 12, 1996.
During a closeout of a licensee event report, the inspectors identified a non-cited violation
for failure to meet Technical Specifications testing requirements of the emergency escape
air lock (Section EB.3).
- Plant Support .
The inspectors concluded that radiological practices observed during the maintenance
activities and plant daily walkdowns were adequate.
3
Report Details
Summary of Plant Status
The plant operated at full power for the entire inspection period.
I. Operations
01
Conduct of Operations
01.1
General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations. The conduct of
operations was considered by the inspectors to be good; specific events and noteworthy
observations are detailed below.
01.2
Component Cooling Water Leak
a.
Inspection Scope (71707 and 40500)
On January 1, 1998, a loss of component cooling water (CCW) inventory occurred which
was greater than the CCW surge tank makeup capacity. The inspectors followed up on
the circumstances surrounding the event, the licensee's investigation, and the corrective
actions for the loss of CCW.
b.
Observations and Findings
Event Description:
On December 24, 1997, plant operators identified a leaking air solenoid on the radwaste
evaporator CCW return valve, CV-09778. After discussing the leak with system
engineering and management, the operators decided to place CV-09778 in its safety
function position by closing the valve. Closing CV-09778 resulted in isolating CCW flow
and pressurizing the cooler to full CCW system pressure. Because there was no
immediate need to process radioactive waste, the licensee planned to repair the valve
two weeks later.
On December 28, 1997, the operators identified a CCW leak on the "A" radwaste
evaporator distillate cooler head gasket flange. The leak was approximately 100 milliliters
per minute. On the following day, the fix-it-now team determined that tightening the
flange could cause the leakage to increase.
On January 1, 1998, the leak rapidly increased to 200 gallons per minute (gpm),
exceeding the CCW surge tank makeup capability of 135 gpm. The operators first
became aware of the problem when a remote panel annunciator alarmed for high level in
the auxiliary building sump. While the operators were taking actions to isolate the "A"
4
evaporator distillate cooler, the CCW surge tank alarm annunciated in the control room.
The operators entered Off Normal Procedure (ONP) 6.2, "Loss of CCW," and isolated the
CCW leak. After the leak was isolated, the CCW system was refilled; however, the
system required several venting evolutions over the following two days.
Operator Response:
After the CCW surge tank alarm annunciated in the control room, the operators entered
Off Normal Procedure (ONP) 6.2, "Loss of CCW." The shift supervisor directed that the
reactor be tripped and primary coolant pumps (PCPs) secured if abnormal CCW pump
operating conditions were noted. These actions were more conservative than the ONP
guidance. Also, the shift supervisor determined that starting a standby CCW pump would
have worsened the low CCW inventory problem and resulted in the air-binding of the
CCW pumps. Therefore, contrary to the ONP, the operators did not start another CCW
pump. The operators recovered surge tank level before CCW flow was disrupted to the
PCPs.
The inspectors concluded that operator response to the event was appropriate and
timely. The operators avoided a reactor trip and potential damage to the PCP seals. The
inspectors also noted that the shift supervisor conservatively decided to trip the reactor
should any significant operational problem occur with the CCW system or PCP seals.
The licensee's incident response team (IRT) noted a weakness in the event response in
that the shift supervisor did not announce the decision not ~o start the standby CCW
pumps to the shift crew.
Also, the licensee failed to recognize the potential for degradation to the CCW system.
Based on the number of venting evolutions, air entrapment in the CCW system was
significant; however, the licensee determined that the system was operable because it
had met system performance requirements. The inspectors concluded that the licensee's
operability determination was weak in that it did not account for the significant inventory
loss and air entrapment.
Incident Response Team Performance:
As documented in Inspection Report No: 50-255/97014, the NRC had identified a
weakness in the licensee's response to the failure to recognize all control rods out of
service while at power. Following the loss of CCW on January 1, 1998, the licensee
established an incident response team (IRT) to investigate the circumstances
surrounding the event. The IRT appropriately prioritized significant corrective actions and
ensured that the actions were completed in a timely manner. Overall, the licensee's IRT
evaluation resulted in a thorough understanding of the event. However, the inspectors
noted several IRT weaknesses. The most significant weakness was that the IRT
personnel did not have a thorough understanding of Generic Letter 91-18 as it applied to
the loss of CCW event. Generic Letter 91-18 addressed operability of systems,
structures and components and the resolution of degraded and nonconforming
conditions. The initial condition report for the loss of CCW surge tank did not recognize
that the CCW system was degraded but operable. Declaring the system inoperable or
degraded would have required an operability evaluation to be documented .
5
Also, IRT personnel did not request an analysis of the loss of CCW event in terms of its
effect on core damage frequency. The inspectors discussed a loss of CCW with the
primary coolant pump system engineer: The in.spectors were concerned that the
licensee's engineering staff did not have an understanding of what would happen to the
PCP seals after a 1 O minute loss of CCW. The licensee is presently discussing thi~
matter with the seal vendor. Another weakness noted by the inspectors was that the IRT
process was not formalized in that it had not been proceduralized. The licensee originally
planned to complete this action item by the end of January 1998. The inspectors
discussed these weaknesses with licensee management and concluded that the
corrective actions taken or planned would adequately address the problems.
c.
Conclusions
The operators responded appropriately to a loss of component cooling water event that
occurred on January 1, 1998. The licensee established an incident response team (IRT)
to investigate the circumstances surrounding the event, and the inspectors concluded
that the IRT's findings and proposed corrective actions were thorough. However, the
inspectors identified several IRT weaknesses, most significantly, the team's lack of
understanding of Generic Letter 91-18 regarding degraded conditions. The inspectors
discussed these weaknesses with licensee management and concluded that the
corrective actions taken or planned were adequate.
01.3 . Nitrogen Station Valve Mispositioned
a .
b.
Inspection Scope (71707)
During performance of surveillance M0-29, "Engineered Safety System Alignment,"
nitrogen bottle isolation Valve MV-N2-126 was found closed. The inspectors reviewed
corrective actions taken for the mispositioning of a nitrogen station bottle isolation valve.
Observations and Findings
The purpose of surveillance M0-29 was to determine by inspection that Technical
Specification (TS) limiting conditions for operations are not being violated by
misalignment of valves, breakers, or controls contained within or affecting engineered
safety systems. Valve MV-N2-126, an isolation valve to a nitrogen bottle associated with
nitrogen station 38, was checked as part of the surveillance and found closed contrary to
its normally open position. The licensee investigated the mispositioned valve. While
performing maintenance on nitrogen station 38, an auxiliary operator closed the supply
valves on the nitrogen header to provide added personnel protection due to a leaking cap
on a test connection. This action was logged in the secondary plant log. However, when
the auxiliary operator went to restore the nitrogen bottle isolation valves,
Valve MV-N2-126 was missed. The inspectors concluded that the safety significance of
this event was minor because the instrument air system was available.
Corrective action for this event was the development of an equipment status control
record. Equipment operated in t.he plant not covered by any controlling document was to
be listed on this record. The inspectors questioned se.veral operators to ascertain
whether or not sufficient controls were in place to review and store completed valve
record sheets. The inspectors found that the record sheets were not being reviewed or
6
saved. The issue was discussed with the operations superintendent, and the operations
superintendent agreed it would be prudent to retain and periodically review the record
sheets.
c.
Conclusions
Following the discovery of a mispositioned valve at a nitrogen station, the licensee
instituted an equipment status control record to enhance the operations department's
. control of equipment. To date, no discrepancies have been identified.
08
Miscellaneous Operations Issues (92701 and 92901)
08.1
(Closed) IFI 50-255/94014-06: Control room ventilation noise was considered a
distraction in the control room. The licensee evaluated this concern from the Diagnostic
Evaluation Team inspection and performed modifications to quiet the airflow. Silencers
were installed by temporary modification TM-95-107 and made permanent by the
engineering specification change SC-95-073. Main control room silencers and a balance
damper were installed under specification change SC-97-027. The inspectors and
operating personnel interviewed have noticed a significant reduction in control room
ventilation noise. This item is closed.
08.2
(Closed) Violation 50-255/96008-01: F'ailure to have a senior reactor operator in the
control room at all times. On August 9, 1996, the control room supervisor left the control
room with no other senior reactor operator (SRO) present. The control room supervisor
entered the viewing gallery, which is adjacent to the control room. The control room
supervisor was out of the control room less than one minute. On August 13, 1996, a
similar occurrence resulted when the shift engineer, who temporarily relieved the control
room supervisor as the SRO in the control room, briefly left to file a work order in the
adjacent technical support center. The shift engineer was out of the control room
approximately one minute. Extensive remodeling of the control room was ongoing in both
instances. In each case, the SRO went to an area that was normally part of the control
room envelope but had been temporarily relocated outside the control room.
Immediate corr~ctive actions for the first event included a reminder in the Daily Orders
regarding control room staffing, and operations management discussed the event with
the involved SRO. Also, the door between the control room and the temporary shift
engineer's desk was closed in an attempt to make it less convenient for an SRO to leave
the control room inadvertently. Operations management discussed with the available
SROs their responsibility to maintain an SRO in the control room at all times. An entry
was also made on the SRO turnover sheet as a reminder for SROs that had not
participated in the discussion.
In addition, the control room remodeling project has been completed. The shift
supervisor, shift engineer and control room supervisor work areas have now been
restored to their normal locations. This item is closed .
7
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II. Maintenance
M1
Conduct of Maintenance
M1 .1
General Comments
a.
Inspection Scope (62707 ~nd 61726)
The inspectors observed all or portions of the following work activities:
Work Order No:
24713751
24713416
24710557
24714900
24510530
24002261
2410939
Surveillance Activities
SOP-3
Q0-23
M1-39
M1-3
M1-3
Q0-21C
PCV-0522A, Alternate steam Sl,lpply to AFW pump P-88:
Calibrate Controller. Steam pressure setting has drifted
below setpoint
P-7C Service water pump: Perform preventive
maintenance on Breaker 152-205
Nitrogen station 1 A: Replacement of check valve and
manifold valves on
SV-09778, CCW return from radwaste evap.: Removal,
replacement and testing of leaking solenoid valve
MV-SFP 131, sperit fuel pool supply valve to shutdown
cooling heat exchanger: Repair body to .bonnet leak
MV-SFP 132, spent fuel pool return valve from shutdown
cooling heat exchanger: Repair body to bonnet leak
MV-SFP 512, instrument isolation valve to spent fuel pool
heat exchanger E-538: Lap valve seat and repair body to
bonnet leak
Safety Injection and Shutdown Cooling System (Safety
injection tank sampling)
Auxiliary Hot Shutdown Panel Instrumentation Checks
Auxiliary Feedwater Actuation System Logic Test
Reactor Protection Matrix Logic Tests
Venting of the CCW System
lnservice Test Procedure - Auxiliary Feedwater Pump P-8C
8
b.
Observations and Findings
The inspectors noted that the work was conducted in a professional and thorough
manner. All work observed was done with the work package present and in active use.
Work packages were comprehensive for the task and post maintenance testing
requirements were adequate. The inspectors frequently observed supervisors and
system engineers monitoring work. When applicable, work was done with the appropriate
radiation control measures in place. Specific events and noteworthy observations are
noted below.
The inspectors noted that the spent fuel pool maintenance activity was well planned and
. executed; however, one deficiency was noted. The nuts and bolts on the valves and at
the job site for contingency use were heat treated steel instead of stainless steel. This
issue is discussed in detail in Section M1 .2.
The inspectors observed the auxiliary operators at the hot shutdown panel. The
inspectors noted that the off-normal procedure and emergency operating procedures
were stored inside the cabinet. The inspectors were concerned that the manuals could
move around during a seismic event and damage control wiring in the panel. A condition
report was generated, and the manuals were removed from the panel. The inspectors
reviewed the operability determination, which was found adequate.
During replacement of two manifold valves on Nitrogen Station 1A, the inspectors noted
that maintenance technicians demonstrated a proper questioning attitude by notifying
their supervisor of a tagout deficiency before starting work on the* nitrogen station.
Operations personnel had removed the hoses from the.nitrogen bottles and tagged the
hoses. This meant that the maintenance technicians would have had to remove the
tagged isolation boundary from the manifold valves, which posed no personnel safety
risk, but was contrary to procedural requirements of Administrative Procedure AP 4.10,
"Personnel Protective Tagging." Operations edited the switching .and tagging order; and
removed the tag.s. Reinstallation of the hoses was covered in the restoration activities.
c.
Conclusions
Overall, the inspectors observed good procedure adherence and maintenance and
radiation work practices. Two identified deficiencies were promptly corrected; however,
the inspectors identified a concern regarding the use of heat treated steel nuts and bolts
on two spent fuel poof valves.
M1 .2
Spent Fuel Pool System Maintenance Outage
a.
Inspection Scope
The inspectors reviewed the licensee's preparatory activities and observed portions of the
spent fuel pool valve maintenance. Discussions were held with the maintenance planner
C!l'1~L~ystem engineer. Observations of the prejob brief, the spent fuel poof draindown
evolution, portions of the valve maintenance activities, and the post-maintenance critique
were conducted .
9
b.
Observations and Findings
The purpose of the spent fuel pool maintenance outage was to repair body to bonnet
leaks on two valves, MV-SFP131 and MV-SFP132. Performance of the repairs required
lowering the spent fuel pool approximately three feet.* This would bring the level below
the suction for the spent fuel pool pumps. Portions of the spent fuel pool system piping
above the valves also had to be drained. The risk of this maintenance activity was
potential loss of positive control over fuel pool level and water temperature.
The inspectors discussed the activity with the system engineer and planner. It was
evident from the procedure and schedule that the activity was well planned. Adequate
controls were in place to monitor spent fuel pool level and temperature. Also, planned
radiological precautions were adequate to account for potential airborne contamination
when the uncovered portion of the spent fuel pool walls dried out and when the spent fuel
pool system integrity was breeched during maintenance activities on the valve bonnets.
The schedule allowed for a sufficient margin to avoid exceeding administrative limits for
fuel pool temperature. Blank flanges were made as a contingency if the system integrity
had to be restored once the valves were apart.
The inspectors observed the tagout and draining of the spent fuel pool and piping. The
activity by the operations shift was well executed and controlled. The inspectors noted
good oversight of the evolution by the shift supervisor. The maintenance activity went'
well; no deficiencies were noted. However, the inspectors noted that the extra nuts and
bolts at the job site for contingency use were heat treated steel. Also, nuts and bolts on
the valves body to bonnet connections were heat treated steel. These should have been
stainless steel, because the spent fuel pool has borated water. The inspectors brought
this to the system engineer's attention. Generic Letter 88-05, "Boric Acid Co.rrosion of
Carbon Steel Reactor Pressure Boundary Components in PWR Plants," and several
information notices have addressed this issue. Also, the inspectors had discussed with
licensee management this concern pertaining to the spent fuel pool system. The
- inspectors considered this issue to be an unresolved item (50-255/97018-02) pending a
review of the licensee's evaluation of the heat treated steel nuts and bolts.
The licensee was reviewing purchase order requirements as to why the steel nuts and
bolts were considered acceptable. The maintenance outage was completed ahead of
schedule. Operations restored the fuel pool system integrity and refilled the spent fuel
pool.
c.
Conclusions
The inspectors concluded that the spent fuel pool maintenance activity to repair body to
bonnet leaks on two valves, MV-SFP131 and MV-SFP132, was well planned and
executed. However, one deficiency was noted in that the nuts and bolts on the valves
were heat treated steel instead of stainless steel. An unresolved item was opened
pending a review of the licensee's evaluation of the nuts and bolts.
10
Ill. Engineering
E1
Conduct of Engineering
E1 .1
Review of Engineering Corrective Actions and Evaluations of Air Systems
a.
Inspection Scope (37551)
On March 18, 1997, CV-3018, Safety Injection Tank Test Line Redundant High Pressure
Injection Isolation Valve, failed to change position during a surveillance test because its
air regulator was plugged with rust. The inspectors reviewed NUREG-1275 Volume 2,
"Operating Experience Feedback Report - Air System Problems.,.. and the.licensee's
corrective actions and evaluation of Generic Letter 88-14. The inspectors also inspected
improvements made to the instrument air system and high pressure air system.
b.
Observations and Findings
One of the licensee's evaluations supporting the response to Generic Letter 88-14,
ATRN-88-55, dated February 15, 1989, stated, in part:
"Another issue to be resolved is the placement of satellite filters in the airlines.
Most of the filters are installed downstream of pressure regulating valves ....
However, the regulators then go unprotected from larger airline particles which
could cause regulator failure."
Inspection Report No. 50-255/97005 discussed the failure of CV-3018 to reposition in
March 1997. In addition to discussing safeguards high pressure air system drawing
discrepancies, the inspection report documented the inspectors' concern about the
placement of the air filters:
"The inspectors reviewed the safeguards high pressure air system drawings and
noted that not all pressure control valves (PCVs) were configured the same ..
Some PCVs had the air filters upstream of the valve, as would be expected.
However, the majority of the filters were located downstream of the PCVs and
system engineering was aware of the discrepancy. However, the inspectors were
concerned that this was a longstanding issue which had not been resolved."
The safety function of CV-3018, a fail-close valve, is to close or remain closed. However,
CV-3018 is opened in Emergency Operating Procedure Supplement 20 for alternate hot
leg injection, and it is also used in Off Normal Procedure (ONP) 25.2 as an optional
- makeup path if all charging pumps have been lost. The filter for CV-3018 was
downstream of the valve; therefore, it was one of the valves previously identified as
susceptible to regulator failure. 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective
Action," requires, in part, that measures shall be established to assure that conditions
adverse to quality are promptly identified and corrected. In 1989, the licensee identified
that filter placement downstream of the valve could lead to regulator failure due to airline
particulate, a condition adverse to quality. In March 1997, CV-3018 failed to reposition as
expected during a surveillance due to airline particulate (rust). The failure to correct an
identified condition adverse to quality is considered a violation of 10 CFR Part 50,
Appendix B, Criterion XVI (50-255/9~018-01 ).
Inspection Report No. 50-255/97005 concluded the discussion of the failure of CV-3018
with the following:
"System engineering has since scheduled PM activities to inspect and clean
selected PCVs; specifically, those that have filters downstream of the PCVs.
These have been determined most susceptible to plugging. System engineering
was reviewing the feasibility of modifications to improve system reportability. One
of the corrective actions instituted to help remove moisture from the high pressure
air system in the west safeguards room was the practice of blowing down the low
point drains on a monthly basis."
On December 2, 1997, the inspectors identified a low point section of the air supply line,
48 feet long, which had no drains, resulting in approximately 6 cubic feet of air line which
could not be drained. CV-3018 was on a downstream section of line which taps off the
48-foot low point section of the air supply line. Therefore, the practice of blowing down
the air.line did not remove moisture from the lines leading to CV-3018, and rust
accumulated to the point where the regulator became plugged. The inspectors
concluded that the low point drain problem and the lack of corrective action for an air filter
placement problem led to failure of the air regulator.
Work request No. 251837 was written on December 3, 1997, to install two new low point
drains in the west safeguards room high pressure air system per engineering assistance
request (EAR) 97-0729. EAR 97-0729 also requested a change to the surveillance
requiring weekly air system blow downs to include these two new locations.
c.
Conclusions
During follow up to a March 1997, failure of CV-3018 to reposition, the inspectors
concluded that the corrective action for air line filter placement for pressure control valves
(PCVs) was inadequate in that the licensee failed to correct a previously identified
condition adverse to quality. The inspectors further concluded that placement of low
point drains in the air lines leading to the PCVs was inadequate. The low point drain.
problem and the la.ck of corrective action for the air filter placement problem led to failure
of CV-3018's air regulator. A violation of NRC requirements was identified.
E1 .2
Radwaste Evaporator Isolation Valve Testing (37551)
a.
Inspection Scope
During recovery from the loss of component cooling water inventory discussed above in
Section 01.2, the licensee noted that some of the radwaste evaporator isolation valves
were leaking by. The inspectors reviewed the licensee's preparations for troubleshooting
the affected valves, CV-0944, component cooling water (CCW) supply isolation valve to
the radwaste evaporators and CV-0977, CCW return isolation valve to the radwaste
evaporators.
b.
Observations and Findings
The inspectors observed the cognizant system engineer brief the control room supervisor
prior to conducting testing of both CCW valves. The system engineer planned to use an
informal guideline to perform the test rather than a procedure. When the control room
12
-*
C.
supervisor questioned the system engineer as to the implications of unisolating the
affected portion of the CCW system, the system engineer did not have a response.
Therefore, the control room supervisor determined that he did not have enough
information to conduct the test.
The inspectors have also identified past weaknesses with informal testing by the
licensee. Examples included the turbine vibration testing that failed to set limits on the
amount of vibration allowed before stopping testing (IR 50-255/97009) and spent fuel pool
rate of temperature rise that had no set temperature limits (IR 50-255/96007). However,
testing performed in accordance with a procedure required a safety evaluation and
management approval.
The inspectors reviewed the activities completed in preparation for valve testing. Design
engineering had prepared an evaluation in the event that one or both of the valves failed
to close during the test. The inspectors reviewed the document and found that various
potential design basis accidents had been addressed. Also, system engineering had
completed an evaluation of all gasketed joints in the radwaste evaporator system. The
remaining gasketed joints had flexitallic gaskets, and the distillate cooler joint had been
properly repaired. System engineering had revised the operability evaluation on the
supply and return valves to include the leakage noted by the valve seats after the loss of
CCW inventory had occurred.
The system engineer held another brief with the control room supervisor and discussed
the completed evaluations. The control room supervisor approved the test and the
testing was completed with no unexpected results .
Conclusions
The inspectors concluded that the system engineer had adequately prepared to perform
leak checks on the radwaste evaporator component cooling water supply and return
valves. However, the inspectors noted that the system engineer did not communicate to
the control room supervisor all of the activities performed in preparation of valve testing.
E1 .3
Motor Operated Valve T-Drain Issue
a.
Inspection Scope (37551)
The inspectors reviewed the licensee's response to a significant events report issued by
another utility that concerned defective T-drains on environmentally qualified motor
operated valves (MOVs). Discussions were held with the component engineering
supervisor, who is responsible for MOVs. The applicable condition report and preventive
maintenance documents were also reviewed to ensure an adequate response to this
concern by the licensee.
b.
Observations and Findings
Recently, two separate utilities discovered vendor supplied T-drains installed on safety-
related MOVs without drilled drain holes. The purpose of the T-drain on the MOV motor
housing is to relieve moisture buildup in a harsh environment following a major accident.
13
c.
EB
E8.1
a.
The vendor supplied T-drains were not drilled and would act as a pipe plug rather than as
a drain. The vendor and other utilities were not able to i.dentify a particular batch or
manufacturing time frame for the defective parts.
This condition was identified at Palisades on November 6, 1996, during inspection of a
new motor. However, the potential generic industry implications were missed. Following
the identification of this problem (C-Pal-96-1338), several corrective actions were
implemented. Spare T-drains and environmentally qualified motors were examined to
ensure a proper drain path had been drilled; all T-drains and motors were found
acceptable. Additionally, the procurement engineering check list (PEC-93-001-0010) was
revised to require receipt inspection of T-drains and the T-drains on motors. Following
the recent identification of a similar problem at other utilities, the licensee revised the
preventive maintenance procedures to ensure a more thorough inspection of the
T-drains.
The licensee reviewed the test data for the 15 environmentally qualified MOVs installed
inside containment which have T-drains. Based on a review of the original test procedure
and engineering judgement, the licensee declared the potentially affected MOVs
operable. The licensee's engineering staff also concluded that the environmental
parameters from the original test procedure were acceptable for qualification at Palisades
for new motors. The inspectors reviewed the licensee's operability evaluation and
associated documentation and had no concerns.
Conclusions
The inspectors concluded that the licensee's response to a generic issue regarding motor
operated valve T-drains was adequate. The inspectors had no concerns with the
licensee's operability determination.
Miscellaneous Engineering Issues (92700 and 92903)
Enforcement Panel Review of Appendix R Issues
Inspection Scope
A NRC enforcement panel reviewed the licensee's corrective actions taken in response to
three reportable Appendix R 50. 72 events involving conditions outside the design basis.
The three Appendix R design issues pertained to: 1) improper evaluation for the effects
caused by spurious operation of component cooling water/service water interface valves;
2) alternate shutdown procedures that did not incorporate the Appendix R assumption
that all reactor c_oolant pumps would be tripped if a fire caus.ed an evacuation of the
control room; and 3) inadequate evaluation for the effects caused by spurious openfng of
the atmospheric steam dump valves. Details of the first two issues were outlined in
Inspection Report No. 50-255/97011. Details of the atmospheric dump valves were
outlined in licensee event report (LER)97-010.
b.
Observations and Findings
The three Appendix R issues were reviewed by an NRC enforcement panel on
October 30, 1997, including the licensee's corrective actions.
14
Design Issue One
On September 12, 1997, the licensee made a one hour nonemergency 10 CFR 50.72
notification for being in a condition outside of design bases. The Appendix R event
involved a control room fire, which generated a hot short condition of a control valve
solenoid resulting in a spurious actuation of a service water (SW) system interface valve.
The part of the SW system involved was the seal cooling water for the essential safety
system (ESS) pumps. The most limiting scenario calculated that only 25 seconds would
be available to close engineering safeguards pump cooling service water return valve,
CV-0951. This valve is *normally closed. An open item of this Appendix R analysis
acknowledged the 25 second requirement, but concluded since the ESS pumps are not
running during normal operation and the component cooling water (CCW) supply and
return Valves (CV-0913 and CV-0950, respectively) to the ESS pumps' sealing cooling
piping are normally closed, then the spurious opening of any one CCW/SW interface
valve could not result in the loss of CCW inventory. Based on this information, another
analysis did not consider actions for the required time period. This reasoning is in error
because CV-0913 and CV-0950 are normally open and fail open on loss of air or loss of
electric power. A single spurious operation of CV-0951 would require a 25 second
operator response to mitigate the consequences, which is not possible.
On September 24, 1997, permanent placards were placed in the control room to indicate
that the air supply valves were permanently closed. The valves were also placed on the
system checklist with the normal position indicated as "closed."
Design Issue Two
On September 23, 1997, the licensee reported the second issue to NRC via a
10 CFR 50.72. It involved the Appendix R analysis assuming all four primary coolant
pumps being tripped if the fire causes an evacuation of the control room. The Off Normal
Procedure (ONP) for Alternate Shutdown did not reflect the analysis and only directed the
operators t6 trip two of the four primary coolant pumps.
Procedure ONP-25.2, "Alternate Safe Shutdown Procedure," did not specifically address
securing all the primary coolant pumps when the operators lose the ability to monitor the
pumps, such as during a control room evacuation or a damage to the instruments.
Procedure ONP 25.2 provided guidance for fires where a control room evacuation was to
take place and fires where the control room is still manned. The procedure assumes that
monitoring of the primary coolant pumps is a condition of their continued operation.
Several fire scenarios could result in a loss of component cooling water (CCW) to the
primary coolant pump seals and bearing coolers. Upon leaving the control room,
operators do not have primary coolant pump monitoring capability or instrumentation to
monitor the CCW system. The licensee's design basis for the primary coolant pumps
indicated they are designed to operate without seal cooling for periods of up to ten
minutes. Immediate corrective action was to initiate a. procedure revision to direct
operators to trip all four primary coolant pumps prior to control room evacuation.
Operator training includes the necessity of CCW for primary coolant pump for operation,
therefore the operators may secure primary coolant pumps when CCW could no longer
be monitored .
15
Design Issue Three
On September 30, 1997, the inspectors were notified of a design vulnerability involving
the inadvertent simultaneous opening of all four atmospheric steam dump valves
discovered during a review of Appendix R documents. The event which may trigger this*
response is a smart hot short in any one of. three cable segments not previously
identified. The three cable/wire segments are in the atmospheric dump control circuitry,
and are physically located in two main control room panels and in a section of cable
routed in a raceway in the cable spreading room.
The event involves a fire that causes a single hot short iil the control room panels or a
single hot short in the cab.le spreading room that could potentially result in all four
atmospheric dump valves (ADVs) spuriously opening. An engineering analysis was
conducted for a plant response with only two stuck open ADVs under Appendix R
conditions. The analysis concluded that spurious operation of the control circuit during a
fire scenario would only affect two ADVs because the review was limited to only the
circuits identified on the circuit and raceway schedule. A cable routed between the cable
spreading room and the control room where a hot short could exist and cause the
deficient condition is not identified on the circuit and raceway schedule, contrary to what
is normally expected. Additionally, original plant design and construction practice
excluded wire and cable within the various panels in the plant from inclusion in the circuit
and raceway schedule. Rather, such* wire/cables are described in vendor prints for the
specific panels, not in the original architect engineering's cable and raceway schedule.
Thus, the scope of review of cable and raceway schedules excluded cables located
internally to specific panels.
The level of plant knowledge of those involved in the analysis also contributed to the
condition. Had they been aware .that a single controller operated the four ADVs, it is
expected the decision to only evaluate a condition with two AOVs opening would have
been questioned. A lack of adequate rigor in the analysis of the control circuits led to not
identifying this single common control feature.
The licensee performed an analysis and provided evidence that operators could close the
AOVs within six minutes. Procedure ONP 25.2 was revised to ensure the actions are
completed within the required time. Engineering is completing a new plant analysis
response to address the opening of all four ADVs during the postulated fire scenarios.
The Appendix R group is continuing to perform an in-depth review of Appendix R. This
effort is expected to conclude in early August 1998.
c.
Conclusions
These issues are of concern* because of the safety significance associated* with plant
equipment configuring that did not meet 10 CFR Part 50, Appendix R, safe shutdown
requirements for a design basis fire. These issues would normally be designated as a
Severity Level Ill problem in accordance with the NRC's NUREG-1600, "General
Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement
Policy). However, enforcement discretion will be used in accordance with Section Vll.B.3,
"Violations Involving Old Design Issues," of the Enforcement Policy and a Notice of
Violation will not be issued. The decision to apply enforcement discretion was based on
consideration of the following: 1) significant NRC enforcement action (EA 96-131) was
16
"
taken against the Consumers Energy Company for several examples of a failure to take
prompt corrective actions related to Appendix R deficiencies. Palisades identified the
issues detailed above and promptly notified the NRC; 2) corrective actions were
immediate and encompassed the root causes for these issues; 3) some of the issues
were related to activities that were in progress before the enforcement action was issued;
4) the issues would not be classified at a severity level higher than Severity Level Ill; and
5) Consumers Energy Company met with the NRC to explain their efforts to resolve these
issues, which were outlined in their reply dated September 12, 1996.
EB.2
(Closed) Unresolved Item No. 50-255/91014-01: Failure to perform a between-the-seals
test of the escape air lock. The inspectors found that the same issues of
LER 50-255/97-002 discussed in Section EB.3 of this inspection report, were pertinent to
the closeout of this unresolved item. This item is closed.
EB.3
(Closed) Licensee Event Report No. 50-255/97002-00: Failure to perform a between-the-
seals test of the escape air lock after each use of the air lock. 10 CFR, Appendix J,
requires that air locks opened during periods when containment integrity is required shall
be tested within three days after being opened. Also, testing did not meet TSs, which
required testing subsequent to the air lock door being opened.
Past TS surveillance testing of the escape air lock at containment design pressure with
strongbacks in place caused the seals to deform due to the door design. After
completion of the full pressure test, the doors must be opened to remove the strongbacks
and verify seal contact with the door seating surface to ensure th~t the seals have
rebounded to their pre-test condition. However, past test performance has shown that
after the strongbacks are removed, the seals may not fully rebound, leaving gaps in the
contact surface. After full pressure testing, a seal check was performed as part of the
surveillance test. If the seal contact check revealed gaps, a seal adjustment was
performed to ensure that the seal material rebounded to its pre-test condition. The
licensee considered seal adjustment a normal part of restoration from testing that was
controlled by procedure.
The licensee proposed a TS change and exemption to revise the test requirements. The
change allowed performance of a seal contact check instead of an unrestrained between-
the-seals test for the emergency escape air lock doors. The licensee also proposed
changes to clarify the pressure requirements for the personnel airlock doors between-the-
seals test. The test would be performed at less than or equal to 1 O psig instead of
55 psig.
In a letter dated September 30, 1997, the NRC granted the TS change and exemption
from the requirements of 10 CFR Appendix J relating to the testing of the emergency
escape lock. The exemption provided relief from the requirement to perform additional air
lock leakage rate testing after opening the doors for post-test restoration of seal
adjustment following air lock leakage rate testing. This item is closed.
EB.4
(Closed) Violation No. 50-255/96010-03: Failure to initiate a condition report upon
discovery that Palisades was potentially susceptible to the problems noted in NRC
Information Notice 96-45, "Potential Common-Mode Post Accident Failure of Containment
Coolers." The reason for the violation was due to weaknesses the inspectors identified in
the industry event review program and Administrative Procedure AP 3.03, "Corrective
Action Process." Administrative Procedure AP 3.16 lacked guidance about what types of
17
..
-*
information would warrant transferring an issue out of the industry experience review
program and into the corrective action system. It was also weak in the guidance provided
regarding processes of conditions discovered during the evaluation of industry experience
information that could potentially be a safety concern for the plant. In addition, the
guidelines provided in AP 3.03 as examples of when a condition report should be written
were vague in their treatment of issues being processed.
Procedure AP 3.16 was revised to include guidance for reporting conditions that could
potentially be a safety concern for the.plant which are discovered during the review of
industry experience events. The guidance included elevation to higher management
levels when industry experience information is reported as applicable by multiple facilities.
Procedure AP 3.03 was also revised to clarify when a condition repqr:t, should be written
for items being processed within the industry experience program. These procedure
revisions strengthened the interrelationship between the industry experience review
program and the corrective action program.
The licensee also improved the industry experience review organization and program. An
individual with a technical background was assigned as coordinator of the program. The
new coordinator visited several sites to review other licensees' programs. The
coordinator held briefings with engineering to discuss the purpose and changes being
made to the industry event review program. The industry event program was
incorporated into the program health assessment process for closer management
oversight. This item is closed.
IV. Plant Support
R1
Radiological Protection and Chemistry Controls (71750)
During the resident inspection activities, routine observations were conducted in the
areas of radiological protection and chemistry controls using Inspection Procedure 71750.
no discrepancies were noted.
S1
Conduct of Security and Safeguards Activities (71750)
During normal resident inspection activities, routine observations were conducted in the
areas of security and safeguards activities using Inspection Procedure 71750. No
discrepancies were noted.
F1
Control of Fire Protection Activities (71750)
During normal resident inspection activities, routine observations were conducted in the
area of fire protection activities using Inspection Procedure 71750. No discrepancies .
were noted.
X1
Exit Meeting
The inspectors presented the inspection results to members of the licensee management
at the concl1,1sion of the inspection on January 27, 1998. No proprietary information was
identified by the licensee.
18
"
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. A. Fenech, Senior Vice President, Nuclear, Fossil, and Hydro Operations
T. J. Palmisano, Site Vice President - Palisades
G. 8. Szczotka, Manager, Nuclear Performance Assessment Department
D. W. Rogers, General Manager, Plant Operations
K. M. Haas, Acting Director, Engineering
S. Y. Wawro, Director, Maintenance and Planning
R. J. Gerling, Manager, Design Engineering
P. D. Fitton, Manager, System Engineering
T. C. Sardine, Manager, Licensing
J. P. Pomeranski, Manager, Maintenance
D. G. Malone, Shift Operations Supervisor
M. P. Banks, Manager, Chemical & Radiation Services
E. Chatfield, Acting Manager, Training
19
" -
IP 37551:
IP 61726:
IP 62707:
IP 71707:
IP 71750:
IP 83750:
IP 92700:
IP 92701:
IP92702:
IP 92901:
IP 92902:
IP 92903:
INSPECTION PROCEDURES USED
Onsite Engineering
. Surveillance Observations
Maintenance Observation
Plant Operations
Plant Support Activities
Occupational Radiation Exposure
Licensee Event Reports
Followup
Followup on Corrective Action for Violations And Deviations
Followup - Operations
Followup - Maintenance
Followup - Engineering
ITEMS OPEN
50-255/97018-01
Inadequate corrective action for safeguards high pressure
air system filter placement
50-255/97018-03
50-255/91014-01
50-255/94014-06
IFI
50-255/96008-01
50-255/96010-03
50-255/97002-00
LER
Use of heat treated steel nuts and bolts on spent fuel pool
valves
ITEMS CLOSED
Failure to perform a between the seals test
Control room ventilation noise considered distraction in
control room
Failure to have a senior reactor operation in the control
room at all times
Failure to initiate a condition report
Failure to perform a between the seals test of the escape
air lock after each use of the air lock
20
A LARA
ccw
CFR
CR
CV
GL
GPM
IP
LCO
LER
MO
MV
NRC
NCO
ONP
oos
QO
TM*
TS
LIST OF ACRONYMS USED
As Low As Reasonably Achievable
Administrative Procedure
Component Cooling Water
Code of Federal Regulations
Condition Report
Control Valve
Division of Reactor Projects
Generic Letter
Gallons Per Minute
Inspection Procedure
Incident Response Team
Limiting Condition for Operation
Licensee Event Report
Monthly Operating (procedure)
Motor Operated Valve
Manual Valve
Nuclear Regulatory Commission
Nuclear Control Operator
Off Normal Procedure
Out Of Service
Primary Coolant Pump
Pressure Control Valve
Pressurized Water Reactor
Quarterly Operations (procedure)
System Operating procedure
Senior Reactor Operator
Technical Specification
Unresolved Item
Violation
21