IR 05000255/1985026

Insp Rept 50-255/85-26 on 851008-1122.No Violation or Deviation Noted.Two Unresolved Items & Four Open Items Identified.Major Areas Inspected:Licensee Activities Re Third Auxiliary Feedwater Pump

ML20138M789
Person / Time
Site:	Palisades
Issue date:	12/13/1985
From:	Mccormickbarge, Ring M, David Williams NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138M767	List: IR 05000255/1985026 ML20138M765
References
50-255-85-26, NUDOCS 8512230160
Download: ML20138M789 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report-No. 50-255/85026(DRS)

Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jacksor., Michigan 49201

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Facility Name: Falisades Nuclear Generating Plant Inspection At: Covert, Michigan Inspection Conducted: October 8 through November 22, 1985

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Inspector: D. L. Williams 12//2h5 Date i Barger /

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Approvcd By: f /

Test Program Section Date Inspection Sumary Inspection on October 8 through November 22, 1985 (Report No. 50-255/85026(DRS))

Areas Inspected: A routine safety inspection to verify licensee activities for testing and declaring a third auxiliary feedwater pump operational. Areas inspected included: review of testing procedure and of completed test packag This inspection involved 50 inspector-hours onsite including 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> onsite during offshifts and 18 inspector-hours in-offic Results: Of the two areas inspected, no violations or deviations were identified that require actions by the licensee. However, two unresolved items and four open items were identified that require additional actions by the licensee and the NRC or both, pu22;gg g;ayay G

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DETAILS P_ers_onsl _ Contacted

• J. F. Firlit, Plant General Manager

• R. A. Fenech, Plant Licensing Administrator

• D. G. Malone,. Senior Engineer, Licensing-

• Y. Yeisley, Senior Engineer, Nuclear Assurance Department

• J. D. Alderink,-Superintendent, Hechanical Engineering and Maintenance

• R. L'. Blow, Administrative Supervisor, E and F0

• V. J. Beilfuss, . General Engineer, Mechanical Department

• D. _A. Bixel Senior System Engineer T.' R. Steffler, Project Testing Supervisor, E and F0

• Denotes those personnel present at the exit intervie '

Additional istation technical and administrative personnel were contacted by the inspectors during.the course of the inspectio . History of Modifica_ tion to Auxi_liaryAdwa_ter_Jystem The original design of the auxiliary feedwater system at Palisades

' Nuclear Generating Plant located both pumps in.the same room. The potential for. a comon mode failure (i.e., flooding) initiated a modification to. improve the reliability of the system. The response to

~ Generic Letter _83-37 and Item II.E.1.1 of NUREG-0737,- Long Term Auxiliary Feedwater_ System Evaluation, was a comitment to install a third auxiliary feedwater pump. The licensee has chosen to use an existing High Pressure Safety Injection (HPSI) pump for this comitment. The original design included three HPSI pumps. A safety evaluation by the Office of Nuclear

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Reactor Regulation for support of Amendment 83 of the operating license approved the change of application of.the HPSI-pump to an auxiliar feedwater. pump. An inspection team consisting of M. L. McCormick-Barger and D. L. Williams of the Test Program Section was ' assigned-the ,

responsibility of -verification of the licensee's actions concerning this modification. The activities that were the subject of this inspection were the adequacy of the test. procedure, and the adequacy of test results to meet the requirements and comitments of the licensee. - ReviewofTest-Pro _cedureGM0-8_3_4_3dO1 The test procedure was reviewed to verify that it complied with the guidance in Regulatory Guide 1.68, Appendix C, for preparation of test procedures. The procedure possessed tne following detailed features:-

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Scope and objectives Limitations Precautions Prerequisites

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5) Acceptance criteria .

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6) System lineups '

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7) Checkoff lists that-irclude provisions for:

(a Recore..ig thi rompletion of procedural steps (b Recording observed values of parameters (c Recording observ6d deficiencies (d Ideletifying personnel conducting the test procedure and perferming individual steps (e) Recording of completion of system restoration The inspector also verified that the preparation of the test procedure included the appropriate levels of review and concurrence by members of the licensee's staff The test procedure was also reviewed for technical adequacy. This included determining if the test would verify the commitments in the Updated Final Safety Analysis (UFSAR), the commitments in response to NUREG-0737, Item II.E.1.1, the comitments by the licensee made in the licensing amendment and the requirements contained in the proposed Technical Specification. The inspector had the following

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comments: -

(1) During the check of logic and initiation of components, the licensee's procedure utilizec test switches. The inspector was unfamiliar with these test switches and how they interfaced with the various components that were tested. After reviewing

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logic and wiring diagrams and conducting thcrough discussions with licensee's staff engineers, the inspector's concerns about the use of these test switches or their impact on the reliability of the system were all adequately reso_1ve ,

(2) During operational testing of the pumps, the emergency power supply was only simrdated. When verifying the proper initiation and operation of sa Mty-related components, a simulation is not considered adequate. In order to prove operability, the components must be subjected to an actual initiation and sequenced loading on emergency power. The inspector reviewed a completed surveillance test, R0-8, Revision 22, " Engineered Safeguards System," that was Nompleted on July 22, 1984. This surveillance procedure adequately tested the features. The

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inspector has no further concerns in this. are . Review of Completed Test Results GMO-8343-501 The review consisted of verification of acceptable performance of the system and the identification and resolution of any identified deficient conditions. During the review the inspector. identified the following concerns: , , When te5 ting the "A" auxiliary Yeedwater pump at a flow rate of 150 gallons per minute the"notor required 100 amperes. The maximum ampere rating 1.isted in the, procedure is 101 amperes. The licensee t

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s is currently. evaluating this potential problem and expects to resolve it in the near. future. This item is outside the scope of this inspection; however, this item was identified to the resident inspectors for their information and they will review the resolution of the item, During the review it became apparent that the licensee was experiencing difficulty in retrieving requested document The inspector is unsure if the documents have been improperly stored or may have not been retained as required. In Inspection Report No. 50-255/85017 the licensee was cited for inability to retrieve documents. Apparently the licensee conducted an extensive search and eventually located the documents after approximately three. weeks. While the documents were finally located, the time to produce these documents may not meet the definition of retrievability or provide any useful information to the licensee .

or other parties in a meaningful time frame. This concern was discussed with the inspector responsible for Inspection Report 85017 as additional information to be considered when reviewing the licensee's corrective actio While reviewing the documents associated with this testing activity, the inspector noted several instances of inadequately prepared test deficiencies. The initial description and resolution failed to adequately describe the deficient condition and the resolution failed to adequately define the actions taken to resolve these conditions. The resolutions sometimes utilized other documents to initiate repair, rework or replacement, but the documents were not identified on the test deficiency. This made

. traceability of all of the actions taken nearly impossible. The licensee had previously identified this problem and initiated corrective actions to resolve the identified concerns. The inspector reviewed procedure MT-13, Revision 3 " Deficiency Reports," and procedure E-6, Revision 3. " Construction Release and Turnover." These procedures. appear adequate to resolve the inspector's concerns. The inspector will evaluate the implementation in a subsequent inspection repor The licensee had comitted to complete a 48-hour endurance run and restart after cooldown in response to questions from the Office of Nuclear Reactor Regulations (NRR). During the review and discussions it became apparent that the licensee had not conducted this testing. The inspector considers this a requirement to meet the design requirements and verification of auxiliary feedwater component All new plants that have this equipment have been required to meet this design verification and previously licensed plants were required to verify this design feature as part of the response to NUREG-0737, Item II.E. The licensee has questions about the applicability of this requirement on their utilization of a previously installed HPSI pump as a third auxiliary feedwater

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pump. The inspector has requested any additional documenttition which the licensee may have thatt supports their posii t on. This ,

.is considered an unresolved item (255/85026-01) pending receipt '

and review of the documents and further discussion with NR '

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' Du' ring discussigns with licensee p4rsonWel, it was determined that a flow test through the alternate' suction supply from the service '

water system to'the third auxiliary feedwater pump suction had not

been performed. The inspector considers this a requiremeird as stated in Section 5 of ANSI N45.2.8-1975. The licensee has requested more '

time to gather documents /that wi11' support their opinion that the piping is clear of obstructions and will pass flow when required to mitigate an abnormal event. The inspector discussed other requirements detailed in Section 5 of the ANSI Standard (pressure drop determination, vibration analysis) and has requested that the licensee respond to all described items. This is considered an unresolved item (255/85026-02) pending receipt and review ,

for acceptability by'the inspecto No violations or deviations were identified; however, two areas require further review and are considered unresolved items, s

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5.. Outstanding Inspection Items

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The inspector was unable to complete the inspection as originally planned. In order to complete the inspection and adequately evaluate 1 the testing of the third auxiliary pump, the following items should be accomplished: A review of any Quality Assurance audits and surveillances performed during testing of the pump to evaluate the finding This is censidered an Open Item (255/85026-03) pending the review and evaluatio A walkdown of the installed equipment to verify that current drawings reflect the "as-built" configuration. This is consideredanOpen' Item (255/85026-04) pending this actio < A reviet of. testing / calibration procedures / techniques for pressure and flow transmitters to determine if these activities

, will verify' proper installation. This is considered an Open

Item (255/85026-05) pending completion of this' revie A review of the ffaal technical specification values to determine -

if the data collected during testing meets the required surveillance requirements. '1his is considered an Open Item (255/85026-06) pending the issuance and review of technical specification i ..

i No violations or deviations were identified; however, four areas require further actions and review by the inspector and are considered open item .

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6. Open Items Open items are matters which have been discussed with the licensee which will be reviewed further by the inspectors, and involve some action on the part of the NRC or licensee or both. Open items are discussed in Paragraphs 5.a, 5.b, 5.c, and . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed in the inspection are discussed in Paragraphs 4.d and . Exit Interview The inspector met with the licensee representatives denoted in Paragraph 1 on November 22, 1985. The inspector summarized the scope of the inspection and the findings. The licensee acknowledged the statements made by the inspector with respect to the open and unresolved items. The inspector also discussed the likely 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