IR 05000255/1985013

Insp Rept 50-255/85-13 on 850510-0610.No Violation or Deviation Noted.Major Areas Inspected:Previous Insp Findings,Operational Safety,Maint,Surveillance,Organization & Administration,Lers & Independent Insp Areas

ML20127L392
Person / Time
Site:	Palisades
Issue date:	06/21/1985
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
References
50-255-85-13, NUDOCS 8506280002
Download: ML20127L392 (10)

Text

_ _ _ _ _ _ _

.. .

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-255/85013(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 Plant Inspection At: Palisades Site, Covert, MI Inspection Conducted: May 10, 1985 through June 10, 1985 Inspectors: E. R. Swanson C. D. Anderson Approved By G. .

r' , Chief 4-2/- W Reactor rojects Section 2A Date Inspection Summary Inspection on May 10 through June 10, 1985 (Report No. 50-255/85013(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspector of previous inspection findings; operational safety; maintenance; surveillance; organization and administration; LERs; and independent inspection area The inspection involved a total of 174 inspector-hours onsite by two NRC inspectors including 23 inspector-hours on site during.off-shift Results: Of the seven areas inspected no violations or deviations were identifie PDR 850621ADOCK PDR 05000255 O

I leo 1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

... ..

DETAILS 1. Persons Contacted

• J. F. Firlit, General Manager J. G. Lewis, Plant Technical Director R. D. Orosz, Engineering and Maintenance Manager

• T. J. Palmisano, Plant Projects Superintendent R M. Brzezinski, I and C Engineering and Maintenance Superintendent P. F. Bruce, Electrical Engineering and Maintenance Superintendent W. L. Beckman, Radiological Service Manager C. E. Axtell, Health Physics Superintendent R. M. Rice, Plant Operations Manager i

• C. S. Kozup, Plant Operations Superintendent

• H. M. Esch, Plant Administrative Manager W. M. Hodge, Property Protection Supervisor

• R. A. Fenech,. Technical Engineer

• D. J. Fitzgibbon, Licensing Engineer D. J. Smith, Human Resources Administration

.

• R. A. Vincent, Plant Safety Engineering Administrator

• R. E. McCaleb, Quality Assurance Director

• Denotes those present at the Management Interview Numerous other members of the plant Operations, Maintenance, Technical, Chemistry, Health Physics, corporate staffs, and several members of the contract Security forces were also contacted briefl . Action on Previous Inspection Findings (0 pen) Open Item 255/85009-02: Data was not required to be taken on the first stroke of valves by procedure Q0-05. The licensee agreed to revise the procedure and review others to assure that their intent of obtaining

"as found" valve stroke times is met. This item remains open pending completion of these action No violations or deviations were identifie . Operational Safety The inspector observed control room activities, discussed these activities with plant operators, and reviewed various logs and other operations records throughout the inspection. Control room indicators and alarms, log sheets, turnover sheets, and equipment status boards were

,

routinely checked against operating requirements. Pump and valve controls were verified proper for applicable plant conditions. On several occa-sions, the inspector observed shift turnover activities and shift briefing meeting Tours were conducted in the turbine and auxiliary buildings, and central alarm station, to observe work activities and testing in progress and to

_ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ ___________

. .

observe plant equipment condition, cleanliness, fire safety, health physics and security measures, and adherence to procedural and regulatory requirement On June 6, 1985, the licensee discovered some apparent control rod binding during weekly surveillance testing. Further testing, which included torque traces on the drive motors, showed binding of control rod #31 in the outward direction. After continued testing the rod would not move in the outward direction and was declared inoperable and untrippable at a position five inches below the top of the core at 1645 hours0.019 days <br />0.457 hours <br />0.00272 weeks <br />6.259225e-4 months <br /> on June 6. The licensee recalculated the shutdown margin and Power Dependent Insertion Limit and found that there are no apparent problems with continued operation. Exxon calculated the rod worth to be one of the lowest worth rods. The licensee does not plan to take any additional corrective actions, and continues to operate at 98% power. The Senior Resident Inspector reviewed the situation and requested an evaluation of the effects of long term operation with a misaligned rod. Evaluation using the INCA and XTG codes showed that the mispositioned rod had a negligible affect on the flux profile and other measured nuclear parameter Additional checking of the Control Rod Drive brake coil on June 7 indicated that the brake had failed and was preventing the rod from being driven in. The licensee declared the rod trippable since the failed brake is disconnected from the rod during a reactor tri No violations or deviations were identifie . Maintenance The inspector reviewed and/or observed selected work activities and verified appropriate procedures were in effect controlling removal from and return to service, hold points, verification testing, fire prevention / protection, and cleanliness. The following activities were reviewed / observed:

85-SFP-008 Repair of flange leak on Spent Fuel Pit heat exchanger 84-EPS-055 Repair of fire seal 85-EPS-076 Diesel 1-1 aftercooler 85-EPS-079 Test repair jacket water to Diesel 1-1 turbocharger 85-EPS-082 Repair jacket water leak on cylinder 9L 85-CVC-111 Repair of FIC 0210 (CVCS makeup control valve)

CCW/24501232 Component Cooling Pump (P-52B) seal repair No violations or deviations were identifie . Surveillance The inspector reviewed surveillance activities to ascertain compliance with scheduling requirements and to verify compliance with requirements relating to procedures, removal from and return to service, personnel qualifications, and documentation. The following test activities were inspected:

.

,

- , _ . - , , _ - . - . . . - , _ . _ . , , _ . _ .

._______

. . Daily Control Room Surveillance - Test D/WO-1 Reactor Protection Trip Test - Test MI-02 Hot Leg Injection Flow Path Test - Test Q0-12 (review only) Post Maintenance Test for D/G 1-1 - Test T-180 No violations or deviations were identifie . Organization and Administration By a letter dated January 11, 1985, Consumers Power Company requested a change to the administrative controls section of the Technical Specifications. This request was due in part to the plant reorganiza-tion that took place in November 1984. The request also incorporates the overtime guidelines of Generic Letter 82-12 and the 10 CFR 50.54(m)

requirements for the minimum number of licensed operators onsite. This request is still under review by the Office of Nuclear Reactor Regulatio The licensee briefed the NRC Region III office of the management changes prior to their implementation. The inspector ascertained that the licensee's organization is functioning as described in the proposed Technical Specifications. A review of personnel records was made to verify that those persons occupying responsible management positions met the qualification levels in the Technical Specification required by ANSI Standard N18.1-1971 and Regulatory Guide The Palisades General Manager, Mr. J. Firlit, appears not to have the required years of responsible power plant experience stated in ANSI Standard N18.1-1971. Section 4.2.1 of the Standard states when one or more persons who are designated as principal alternates for the plant manager and who meet the nuclear power plant experience and Senior

- Reactor Operator's (SR0) license examination requirements established for the plant manager, the requirements established for the plant manager may be reduced, such that only one of his ten years of experience need to be nuclear power plant experience and he need not be eligible for SR0 examination. A maximum of four years may be fulfilled by academic training for Mr. Firlit since he has a Bachelor of Science in Electrical Engineering degre The remaining six years of responsible power plant experience is the requirement of the standard that Mr. Firlit does not mee The Office of Nuclear Reactor Regulation has agreed (per the telephone conversation of May 30, 1985 betwee T. Wambach and C. Anderson)

to resolve this issue with the licensee as part of the proposed change to the administrative section of Technical Specifications. Until this issue is resolved it is considered an open item (255/85013-01(DRP)).

An inspection of selected radiation protection and chemistry personnel was previously made by regional specialists and documented in reports 255/85004 and 85010(DRSS).

.

,-

- ,

._____ _________________

. .

The inspector also reviewed the associated administrative procedure for personnel selection, qualification and certificatio A few minor discrepancies were noted between the standards and the procedure and were discussed with the Acting Personnel Director for consideration for an upcoming procedure revisio An orde'r dated March 14, 1983 states that the licensee has completed the requirement of revising administrative procedures to limit overtime in accordance with the NRC Policy Statement issued by Generic Letter 82-1 Instead of having a procedure, the licensee has implemented the overtime limitations with a Station Policy dated September 29, 1982. Policies do not receive the same amount of review and approval as procedures. Also, the Consumers Power Company Nuclear Operations Department Standard N0DS-P15 " Shift Operations", section 5.1.4 states " Plant working hours and shift personnel work limits shall be defined by the Plant Adminis-trative Procedures." A temporary change to Administrative Procedure was made effective February 14, 1985, but was cancelled after 60 day The temporary change was reissued June 4, 1985 and a permanent change to the procedure is still in the review proces Finalization of this procedure is considered an open item (255/85013-02(DRP)).

The Generic Letter states that deviations from the overtime guidelines are to be authorized by the plant manager or his deputy, or higher levels of management. It appears from departmental policies that give more specific guidance on how to implement the Station Policy, that the Duty and Call Superintendent may authorize deviations. Palisades Administra-tive Procedure 4.00 " Operations Organization and Responsibilities,"

allows even the Lead Shift Engineer and Operations Supervisor to be Duty and Call Superintendent This low level of management does not meet the intent of the Generic Letter which was further clarified by the Office of Nuclear Reactor Regulation in a memorandum to C. E. Norelius of Region III dated October 28, 198 The clarification states that only senior management officials should be able to authorize major deviations from the overtime guidance. The term " deputy" was intended to mean the principal assistant to the plant manager. This failure to limit the overtime deviation authorization authority to senior management is considered an open item (255/85013-03(DRP)).

,

Item 1.C. of the st. tion policy states, "A break of at least eight hours

! shall be allowed between scheduled work periods." By using the phrase

! " scheduled work periods" a situation could arise where someone could work longer than scheduled on one shift, e.g. 8:00am to 5:00pm, and return for his next scheduled shift. e.g. at midnight, which is less than the Generic Letter eight hour break between work periods. This discrepancy is considerea an open item (255/85013-04(DRP)). Through discussions with licensee personnel, the inspector found that the policy at Palisades is to limit the amount of overtime as much as possible. In practice, overtime is used to compensate for illness and scheduled vacation The inspector attempted to review past authorizations given to exceed the guidelines. Although one authorization was found by the licensee, it

.

appears that there is not a good mechanism for documentation or retrieval of any documentation. Two licensee individuals can recall instances where approvals were given but no documentation could be found. The lack of a documentation system is considered an open item (255/85013-05(DRP)).

No violations or deviations were identifie . Licensee Event Reports Through direct observations, discussions with licensee personnel, and review of records, the following reportable events were examined to determine that reportability requirements were met, immediate corrective action was accomplished as appropriate, and corrective action to prevent recurrence has been accomplished per Technical Specification (Closed) LER 255/83-074: During testing twenty three of twenty four main steam relief valves lifted at pressures exceeding the limits of the FSAR and Surveillance Test acceptance criteria. Fourteen exceeded the limits of Technical Specification 3.1.7.c. The cause was attributed to blowdown ring adjustments made during previous outage testing. Blowdown ring adjustment was not expected to have an effect on lift pressur Procedures have not yet been modified to prohibit adjustment to the "as found" or "as left" condition of the valves. Completion of this corrective action (Palisades Event Report 83-204) is an open item (255/85013-06).

The licensee analyzed the impact of the increased lift pressure on four transients which challenge the secondary safety valves. Rod withdrawal from 102% and 52% power, single control rod withdrawal, and loss of load were analyzed using engineering approximation The licensee concluded that the plant was not in an unsafe cordition due to the improperly set valve The LER is close (Closed) LER 255/84-002: During refueling on April 1, 1984, operators inadvertently struck the containment area monitor which caused automatic actuation of containment isolation. The LER did not identify the specific cause of the spurious actuation or the component responsible.

l The licensee has been asked to evaluate the seismic qualification of the l Engineered Safeguard Features equipment which caused the spurious l actuation. This is an open item (255/85013-07). The LER is closed.

l (Closed)- LER 255/84-003: A hanger on the Auxiliary Feedwater (AFW) line

'

to the "B" steam generator was found disconnected from its strut on February 20, 1984. The licensee also found other nuts, bolts, and

,

washers to be missing during subsequent walkdowns of the AFW line Their investigation concluded that vibration of the AFW riping during the previous operating cycle was responsible for the conditions foun On March 30, 1984 a 10 CFR 50.72 report was made concerning the potential

inability of the AFW system to withstand the postulated seismic event.

l The licensee's analysis concluded that the inoperable hanger would result l in the piping being overstressed during the postulated seismic event.

.

The LER is closed.

!

l 6 l

- _ _

_ -_ _ _ . _

. .

(Closed) Special Report 255/84-006: Acknowledgment of receipt of a waste shipment was not received by Palisades Nuclear plant as required. It was found that the receiving facility had not transmitted written acknowledgment until after the licensee's investigation identified their error. This report was submitted pursuant to 10 CFR 20.311(h)(2) and is close (Closed) LER 255/84-008: On June 29, 1984, with the plant at 250 degrees F and shutdown boron concentration, leak testing of the personnel airlock door seals yielded unacceptable results. The leakage, when added to the total leakage from all containment penetrations, exceeded the allowable leakage L This condition existed for two and a half hours. The licenseefe.els that the installation of strongbacks for the "between the doors" test misaligned the seals on the inner door. The licensee met the action requirements of Technical Specification 3.6.1 as interpreted in a letter from D. P. Hoffman (CPCo) to A. Schwencer (NRR) dated November 10, 197 The LER is close (Closed) LER 255/84-010: Thermal degredation of cable insulation due to a fire barrier was discovered on July 3, 1984. Cables were repaired by splicing and the fire barrier was redesigned to improve heat dissipatio Temperature monitors were installed and utilized as agreed under a Confirmatory- Action Letter of July 13, 1984. Actions were completed as documented in Report 50-255/85009(DRP), Paragraph The LER is close (Closed) LER 255/84-015: On August 4, 1984, loss of turbine control fluid caused a turbine trip and reactor tri The one malfunction noted was the failure of the Safeguards Bus 1-C to fast transfer to startup power requiring the Emergency Diesel to start and pick up the load The cause of the failure remains unknown. This event is similar to LERs84-001 and 85-005. Licensee action to correct the cause of these failures will be tracked under open item 255/85013-08. The LER is close (Closed) LER 255/85-003: The licensee was unable to perform Reactor Internals Vibration Monitoring as required by Technical Specification (T.S.) 4.1.3. As a result of hardware failures in data processing

. equipment, vibration monitoring was not performed for a weekly test in November, 1984 and has-not been obtained as specified in the T.S. since February 11, 198 Due to the expense of new equipment and time required for software modifications, the licensee procured equipment necessary to record the data and will send the data to a vendor for evaluation every 90 days, The Director of the Office of Nuclear Reactor Regulation has been notified of the licensee's plans, and a request for a T.S. change has been submitte The licensee considers their report to be " voluntary" in that no limiting condition for operation was exceeded by not performing the surveillance tes The specification did not address actions to be taken if monitoring instrumentation were inoperable, nor did it exclude the performance of the surveillance from the basis for plant operabilit The overriding concern related to this event is the extended length of time (six weeks)

!

. _ . . . .- - _ - _

. - - __

. .

which passed before senior management became aware that a continuing violation of the Technical Specifications existe Actions taken after management became aware were appropriat The licensee plans to conduct training sessions for managers and supervisors, many of whom are new, to improve their sensitivity and the timeliness of corrective actions in events such as this, and others involving NRC requirement The LER is close (Closed) LER 255/85-004: A daily heat balance was not performed on April 11, 1985, as required by Technical Specification 4.1.1, item When this was discovered and the heat balance was performed the following day, the Power Range Safety Channels did not require adjustment, indicating that the event had no safety significanc Cause of the event was attributed to personnel erro A supervisor, while reviewing the surveillance, found a blank and filled it in using the data from the latest heat balance on file without checking the date. Since the plant was at a different power level this was caught during a subsequent review. The licensee considers this personnel error to be an isolated event. The LER is closed.

(Closed) LER 255/85-005: On April 14, 1985, during a power reduction due i

to turbine control problems, a transfer of safeguards bus 1C to startup power failed. The actuation of the startup transformer breaker caused the station supply breaker to open but failed to close the startup breake The loss of power to bus 1C caused an automatic emergency diesel generator start and pick up of bus 10. The condition which caused the failure could not be repeated. The licensee placed the IC bus on startup power to preclude the need to transfer and will continue investigation into the cause during the next plant outage. Two prior events of failure of the 1C bus to transfer to startup power intensifies the concern over resolution of the breaker transfer problems. The completion of this troubleshooting effort related to the transfer problem remains an open item (255/85013-08). The LER is close No violations or deviations were identified.

.

8. Independent Inspection Activities

The inspector made observations concerning radiological safety practices in the radiation controlled areas including

verification of proper posting; accuracy and currentness of area status sheets; verification of selected Radiation Work Permit (RWP) compliance; and implementation of proper personnel survey (frisking) and contamina-tion control (step-off pad) practice Health Physics logs and dose records were routinely reviewe The inspector observed physical security activities at various access control points, including proper personnel identification

<

and search; and toured security barriers to verify maintenance of integri ty. Access control activities for vehicles and packages were occasionally observed. Activities in the Central Alarm Station were observe l

. .

l An ongoing review of all licensee corrective action program items at the Event Report level was performe In response to Temporary Instruction 2515/67 the inspector reviewed the licensee's actions in response to INP0 SOER 85-3 " Auxiliary Feedwater Pumps Disabled by Backleakage". This effort was directed toward validating the effectiveness of the corrective actions taken in response to INP0 initiative No corrective actions had yet been taken with respect to this issue as of early May. Planned accomplishment for this issue was scheduled for June 1, 198 Review of the' licensee action taken in response to SOER 84-2

" Control Rod Mispositioning" found several items that did not appear to be appropriately implemented. These were discussed with the license An Unusual Event (UE) was declared when.two control rods were discovered inoperable at 0251 hours0.00291 days <br />0.0697 hours <br />4.150132e-4 weeks <br />9.55055e-5 months <br /> on May 23, 1985. Rod 24 had been considered inoperable since 0257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br /> on May 9, 1985, when it was not exercised due to existing seal leakage problems with the rod. Rod 31 was driven into the core for the weekly exercising and would not drive out. Fuses were checked and found to be satisfactory. The control switch was then cycled several times and the rod was pulled back out at 0257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br />. Several hours later the rod was again verified operable. The UE existed from 0251 to 0257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br />. The licensee's reports to offsite agencies were late based on late classification of the UE. Training is planned to correct this licensee identified deficienc On May 20, 1985, at 7:58 hours the 1-1 Diesel Generator tripped during an operability *.est due to a jacket cooling water lea The licensee investigated potential leaks in the after-cooler and turbo-charger with negative results. On May 23 they discovered leakage from Cylinder 9L and commenced repairs. A crack was found in the head which the vendor representative (ALCO) believes to be due to the engine overheating when it was run without service water on January 8, 1984 (Loss of AC power and communications - LER 255/84-001). A spare head was available on site, but gaskets and

. hoses were found to have exceeded their shelf life, thus requiring emergency procurement and part retrieval. The licensee also requested a three-day extension to their seven-day Limiting Condition for Operation (LCO) on May 24, 198 Compensatory measures included:

(1) test starting of the alternate diesel (D/G 1-2) and analyzing an oil sample; (2) elimination of the fast transfer to start up power for the associated safety bus by having the bus already aligned to the station startup transformer; (3) administratively preventing the steam driven auxiliary feed pump from being removed from service; and, (4) having the personnel ready to support back-feed if needed (reducing time estimate from six to three hours).

___ _ ___________

!

. ..

The original LCO was to expire at 1413 hours0.0164 days <br />0.393 hours <br />0.00234 weeks <br />5.376465e-4 months <br /> on May 26, 198 Repairs and testing were. completed at 1648 hours0.0191 days <br />0.458 hours <br />0.00272 weeks <br />6.27064e-4 months <br /> on the 26t The inspector observed portions of the troubleshooting, repair and testing of the diese Three concerns were raised with respect to the Standard Operating Procedure No. 22. Section 4.0.h states:

" Engine lube oil prelube pump failure will be cause to run the diesel every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to provide lubrication."

(1) It is not clear why a prelube oil system failure does not render the diesel inoperabl (2) The procedure does not address the vendor (ALCO) manual operating guidance of running the diesel for three minutes unloaded after overheating due to loss of cooling. Failure to incoporate the recommendation may have resulted in thermal cracking of the hea (3) Procedures do not appear to provide adequate guidance for maintenance of the proper oil level in the governor. On May 20, 1985, erratic control problems were resolved by adding oil to the governo Resolution of these concerns remains an open item (255/85013-09).

No violations or deviations were identifie . Open Items Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 6,7 and 8 . Management Interview A management interview (attended as indicated in Paragraph 1) was conducted on June 10, 1985 at the conclusion of the inspection. The scope and results of the inspection were discusse The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar