ML18066A211

Notice of Violation from Insp on 980325-0410.Violation Noted:As of 971114,listed Analyses Were Not Revised When Analytical Inputs Were Changed or Found to Be in Error

ML18066A211
Person / Time
Site:	Palisades
Issue date:	05/18/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18066A209	List: ML18066A208 ML18066A211 ML18066A212 ML18066A213
References
50-255-98-03, 50-255-98-3, NUDOCS 9806290072
Download: ML18066A211 (5)

Text

NOTICE OF VIOLATION Consumers Energy Company Palisades Nuclear Generating Plant Docket No. 50-255 License No. DPR-20 During an NRC inspection conducted from March 25, 1998, through April 10, 1998, six violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action*s," NUREG-1600, the violations are listed below:

A.

Technical Specification 6.5.7, "lnservice Inspection and Testing Program," states, in part, that this program provides controls for inservice inspection and testing of ASME Code Class 1, 2, and 3 components including applicable supports.

American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, IWV-1100, 'Valve Testing," states that valve testing shall be performed in accordance with the requirements stated in OM-10.

Section 1.1, "Scope," of OM-10 states the active and passive valves covered are those which are required to perform a specific function in shutting down a reactor to cold shutdown condition, in maintaining the cold shutdown condition, or mitigating the consequences of an accident.

Contrary to the above, the following valves' functions were not included in the inservice test program although they performed a specific function in shutting down a reactor to cold shutdown condition, in maintaining the cold shutdown condition, or mitigating the consequences of an accident.

1.

As of November 10, 1997, check valves CK-ES3339 and CK-ES3340 in the minimum flow recirculation piping from the discharge of each high pressure safety injection pump had a safety function to close to prevent the potential overpressurization of the pumps suction piping and were not included in the IST Program.

2.

As of March 17, 1998, check valve CK-DMW400 in the flow path from the primary system make-up storage tank T-81 to the condensate storage tank T-2 had a safety function to open, suppling make-up to the condensate storage tank. This check valve was not included in the IST Program.

3.

As of March 17, 1998, control valves CV-1813 and 1814 in the containment purge and ventilation system had an active safety function to close to provide a containment isolation function and were not included iri the IST Program.

4.

• As of March 26, 1998, control valves CV-1501, 1502, and 1503 in the plant heating system had an_active.safety funct[c;m t<;> close to provig~_ ~ _cc:mt~n_r:n_~_nJ__ ---*---- __

isolation function and were not included in the IST Program.

This is a Severity Level IV Violation (Supplement 1 ). (50-255/98003-03) 9806290072 980518 POR ADOCK 050002.55 G

POR

NOTICE OF VIOLATION B.

10 CFR Part 50, Appendix B, Criterion V, "Instruction, Procedures, and Drawings,"

requires, in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.

1.

Administrative Procedure 9.11, "Engineering Analysis," Revision 9, Section 6.1.5.c, states that an analysis shall be revised if analytical inputs changed.

Contrary to the above, as of November 14, 1997, the following analyses, which were activities affecting quality, were not revised when analytical inputs were changed or found to be in error:

a.

The ambient air temperature of 94 °F assumed in Calculation EA-FC-573-2, "Calculated Required Air Flow for Inverter/Charger Cabinet Cooling Fan," was not revised when deficiency report F-CG-91-072 indicated that a design basis temperature of 104 °F should have been used in the calculation. (50-255/98003-04a(DRS))

b.

An assumption regarding pipe break size was not updated in EA-A-NL-92-185-01, "Worst Case Operating Conditions for the LPCl/SDC System MOVs," to determine the effect of the motor operated valves to close against the break when a more conservative pipe break assumption was used in a later analysis EA-C-PAL-95-1526-01, "Internal Flooding Evaluation for Plant Areas Outside Containment," Revision 0.

(50-255/98003-04b(DRS))

c.

Assumptions 5.9 and 5.1 O of EA-A-NL-92-185-01, which stated that the High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) flows to the loops were approximately equal under post-accident conditions were not revised when flow values calculated in EA-SDW-95-001, "Generation of Minimum and Maximum HPSl/LPSI System Performance Curves Using Pipe-Flo, " Revision 2, indicated that Assumptions 5.9 and 5.1 O were incorrect. (50-255/98003-04c(DRS))

d.

The required LPSI injection check valve flows identified in EA-E-PAL-93-004E-01, "IST Check Valve Minimum Flow rate Requirements to Support Chapter 14 Events, " Revision 0, were not revised after a new flow value was calculated in EA-SDW-95-001.

(50-255/98003-04d(DRS))

__ e...

_Electrical calculation EA-ELECT-VOL T-13, "Palisades_ Lo_ss 9f Coolant Accident With Offsite Power Available," Revision 0, was not revised to reflect the load magnitudes identified in EA-ELECT-LDTAB-005, "Emergency Diesel Generator 1-1 & 1-2 Steady State Loading,"

Revision 4, and EA-SDW-95-001.. (50-255/98003-04e(DRS))

This is a Severity Level IV Violation (Supplement 1 ).

NOTICE OF VIOLATION 2.

Procedure MSM-M-43, "Scaffolding," Revision 2, Section 5.3.1, "General,"

requires that in addition to other requirements of this procedure, scaffolding constructed in the vicinity of safety related equipment shall conform to the following seismic requirements:

Suspension scaffolding shall not be used in any plant location which contains safety related equipment without prior engineering and approval and justification documented in Attachment 1, "data Sheet,"

Step 2.6.

Responsible engineer shall provide justification and approval for any scaffold which deviates from the seismic requirements of this procedure, and shall document justification and approval in Attachment 1, "data Sheet," Step 2.6.

Contrary to the above, as of October 6, 1997, engineers had not reviewed the acceptability of scaffolding installed adjacent to the safety related safety injection and refueling water tank. In addition, on October 30, 1997, engineers had not reviewed the acceptability of scaffolding installed in the East engineering safeguards (ESG) room adjacent to safety related piping and documented it on Attachment 1, "data sheet," Step 2.6.

This is a Severity Level IV Violation (Supplement 1 ). (50-255/98003-05(DRS))

3.

Palisades Administrative Procedure 1.01, "Material Conditions Standards and Housekeeping Responsibilities," Revision 11, Appendix 2, requires that unrestrained and potentially damaging items which can topple should be separated from operable safety related equipment by a minimum horizontal distance equal to the height of the item plus five feet.

Contrary to the above, on October 30, 1997, the inspectors observed an unsecured operations storage cabinet within 9 feet of safety related valves CV-0737 and CV-0747A in the West engineering safeguards room which was less than the required 11.5 feet (6.5 feet + 5 feet).

This is a Severity Level IV Violation (Supplement 1 ). (50-255/98003-06(DRS))

4.

Periodic and Predetermined Activity APS025, "Bus 1 C Relay Testing," required testing of the overcurrent relays.

-Contrary to the above, the licensee identified that as of 0Gtob~r 27, _1997, the overcurrent relays for supply breakers 152-105 and 152-106 to Bus 1 C had not been tested. On June 28, 1995, during the 1995 refueling outage, work request 24416160 was issued for their calibration; however, no test results could be located to verify that testing had been completed.

This is a Severity Level IV Violation (Supplement 1 ). (50-255/98003-09(DRS))

NOTICE OF VIOLATION C.

10 CFR Part 50, Appendix B, Criterion Ill, "Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.

Drawing M-74, "Underground Piping Reactor Building," Sheet 1, Revision 10, and Drawing C-155, "Reactor Building Refueling Cavity and Sump Liner," Sheet 2, Revision 12, specify screens oh the inlets of two vent pipes connecting the 590-ft elevation of the containment and the containment sump.

UFSAR Section 6.4.2.3 states that the design of the spray nozzles was reviewed to confirm that the spray nozi:fes are not subject to clogging from debris entering the recirculation system through the containment sump screens.

Drawings J-F-152, "Flow Instrument Above Line WNents - Liquids," Revision 1 and J-F-153, "Flow Instrument Above Line WNents - Liquids," Revision 0, specify a tubing slope of one inch per foot of instrument tubing run for flow transmitters in the High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) systems.

Contrary to the above:

. a.

As of September 26, 1997, two vent pipes which connected the containment sump to the 590-ft elevation of the containment did not have screens installed.

This piping configuration resulted in a pathway for debris to enter the recirculation system without being filtered by th~ containment sump screens and had the potential to clog the containment spray nozzles.

(50-255/98003-07a(DRS))

b.

As of October 24, 1997, instrument tubing to HPSI flow transmitters FT-0308, FT-0310, FT-0312, and FT-0313 and LPS I flow transmitters FT-0307, FT-0309, FT-0311, and FT-0314 was not installed as specified in Drawings J-F-152 and 153, in that it did not have the specified one-inch per foot slope.

(50-255/98003-0?b(DRS))

This is a Severity Level IV Violation (Supplement 1)

Notice of Violation Pursuant to the provisions of 1 O CFR 2.201, Consumers Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should aiso provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 1 O CFR 2. 790(b) to support a request for with-holding confidential commercial or financial information). If safeguards information is necessary tci provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this day of May, 1998