IR 05000255/1985031

Insp Rept 50-255/85-31 on 851203-05 & 1216-20.Violation Noted:Failure to Follow Refueling Procedures Re Use of Loose Hand Tools Over Reactor or Spent Fuel Pool

ML20141H579
Person / Time
Site:	Palisades
Issue date:	01/09/1986
From:	Guldemond W, Milbrot W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141H570	List: IR 05000255/1985031 ML20141H567 ML20141H573
References
50-255-85-31, IEB-84-03, IEB-84-3, NUDOCS 8601140281
Download: ML20141H579 (8)

Text

. .

-

.

.

U.S. NUCLEAR REGULATORY C0ffilSSION

REGION III

Report No. 50-255/85031(DRS)

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: Covert, MI Inspection Conducted: December 3-5 and 16-20, 1985 Inspector: W. Milbrot M e' /- 9-f(2 Date

,fy --

Approved By: W N 1demX d, d ie'f /- 9- f/,

Operational Program Section Date Inspection Summary Inspection on December 3-5 and 16-20, 1985 (Report No. 50-255/85031(DRS)1 Areas Inspected: Routine announced inspection of licensee actions on previous inspection findings, reactor coolant system leak rate testing, refueling preparations, refueling activities, spent fuel pool activities, and licensee actions regarding IE Bulletin 84-03. The inspection involved a total of 57 inspector-hours ensite by one NRC inspector. The inspection was conducted in accordance with inspection procedures 61728, 92701, 60705, 60710, 86700, 92703, and 3070 'Results: In the five areas inspected, one violation was identified (failure to follow procedures - Paragraph 5). ,

'

8601140201 860109 PDR ADOCK 05000255 G PDR

. .

-

-

.

.

l DETAILS 1. _ Persons Contacted ConsumersPowerCompany(CPCol

• J. G. Lewis, Technical Director

• D. J. Fitzgibbon, Licensing Engineer

• A. Fenech, Technical Engineer

• M. Haas, Reactor Engineering Superintendent

• A. Vincent, Plant Safety Engineering Administrator

• D. Orosz, Engineering and Maintenance Manager T. J. Palmisano, Plant Projects Manager C. S. Kozup, Operations Superintendent G. W. Sleeper, Plant Safety Engineering

• R. E. McCaleb, Quality Assurance Director G. Cheesman, Quality Control Supervisor W. J. Axdorff, General Engineer USNRC E. R. Swanson, Senior Resident Inspector C. D. Anderson, Resident Inspector The inspector also contacted and interviewed other licensee personnel during the inspectio * Denotes personnel attending the December 5, 1985 exit intervie dDenotes personnel attending the December 20, 1985 exit intervie . Action on-Previous Inspection Findings (Closed) Violation (255/84-20-03(DRS)): Calibrated stop watches were not required by inservice testing surveillance test procedure The licensee has completed a comprehensive review of all recent tests performed to determine if any tests need to be repeated because of using noncalibrated stop watches. Also, the licensee has revised all surveillance test procedures that require the use of a stop watch to specify that the calibrated stop watch serial number and calibration due date be recorded. Procedures are currently in place that require the validity of test results be reviewed when calibration equipment used by the test procedure are found out of calibratio The licensee is currently reviewing its administrative procedures to determine what changes are necessary to assure that any procedure requiring the use of calibrated equiptrent will specify 'ts use and record the equipment serial number and calibration due dat .

l

.. .- (Closed)OpenItem(255/84-20-01(DRS)): This item documented the fact that the licensee does not maintain pump and valve test data records in a manner that would allow ready identification of conditions adverse to quality. The licensee has implemented a program where pump and valve test data are plotted on a continuous basis cccompanied by an information sheet for documenting test results and maintenance action items. .As new test data is recorded the test results are evaluated by the ISI engineer for possible corrective action. The mechanism is in place to provide trend analysis. A review of the reported infonnation will be conducted by a regional specialist at a future dat . Followup on IE Bulletin 84-03, Refueling Cavity Water _ Seal

_ _ _

As a result of Haddam Neck reactor cavity drain down event of August 21, 1984, the NRC issued IE Bulletin (IEB) 84-03. The IEB required licensees to evaluate the potential for and consequences of a reactor cavity water seal failure and submit a summary report of their finding On November 15, 1984 the licensee submitted the required repor In the report the licensee identified significant design differences between the seal used at Palisades and the seal used at Haddam Neck, seal installation procedure to be followed, the Palisades postulated seal failure accident based upon complete failure of the rubber seal and seating of the seal cover, capacity of available cavity water makeup systems and an assessment of no fuel becoming uncovere During the inspection, the inspector reviewed the licensee's response and supporting information which included the potential for loss of refueling cavity water inventory by means other than cavity seal failure with the following results: The cavity seal used by the licensee is a passive rubber seal held in the one inch wide opening between the reactor vessel flange and refueling deck by a four inch wide steel channel called the seal cover. 'The seal cover is held in place by 36 hold down clamp assemblies equally spaced. The seal cross-section has a gull-wing shape with the heavy radiused center section fitting into the cavity opening and the two wing sections extending out from each side of the seal and then down to make a secondary seal with the vessel flange and refueling flo~or, respectively. The two voids created by the seal side extension sections are pressure tested during installation. The seal cover fits the outer contour.of the seal to hold the seal in place. The legs of the seal cover are of a length designed to contain the seal and still allow the seal to compress as the clamp assembly bolts are tightened, The seal was receipt inspected for cuts, tears, and dirt that could impair its sealing capability. The supplier is required to furnish a Certificate of Compliance verifying that the material furnished meets purchase requirements. A shelf life was established for acceptable seal _

. ,

,. . .. Prior to installation the seal was cleaned and inspected for damag The seal was then placed in the cavity opening and held in place with the seal cover and hold down clamp assemblies. The hold down bolts were torqued to the required load as covered in the procedur The void spaces on each side of the seal, as noted in "a" above, were pressure tested to 12 psig and tested for leaks using a leak detection solution. Should a leak be detected, the seal is rea'djusted and the test repeated. RTV may be used to aid the sealing proces During reactor cavity flooding, Procedure GOP-11, Revision 3,

" Refueling Operations", Attachment 1, requires that the cavity seal area be inspected for leaks and a verification signature complete The steel seal cover will protect the rubber seal from damage caused by items either falling onto the seal or dragged across the sea Also, the seal cover serves as a backup to the rubber seal should the seal be forced through the one inch cavity opening. Should the seal be displaced downward, the seal cover would be forced downward by water pressure keeping the leak rate to a low leve Loss of reactor cavity water is monitored by the Containment Sump Level Alarm. Also, the Spent Fuel Pool (SFP) water level is monitored with an annunciator in the Control Room, The licensee completed a design review of the SFP and fuel transfer mechanism and determined that draining of the reactor cavity would not result in fuel in the pool or transfer tube becoming uncovere During core alterations only fuel in the Refueling Machine and Service Platform have the potential to become uncovered if no operator action is taken. However, assuming complete loss of the cavity rubber seal and subsequent seating of the seal cover, licensee analysis has shown that makeup capabilities would be adequate to maintain cavity water level. Also, refueling personnel are always present whenever fuel is suspended from the Refueling Machine or Service Platform. Operator action to plate the suspended fuel into a safe location could be completed quickly before loss of water level would result in high radiation level As a result of the above action, all fuel assemblies would be covered by a minimum of one foot of water should a seal failure occu . Refueling personnel have been made aware of the potential for a cavity seal failure and the consequences and corrective action to tak A paragraph was added to the precautions section of Procedure-SOP-28,-

Revision 6, " Fuel Handling Systems", to aid fuel handlers in action to take should the SFP or reactor cavity water level begin to decrease rapidl . .

.- .

It is concluded that the' licensee has adequately resolved the issues identified in IEB 84-03 and the IEB is close During the inspection, a review was made to determine if other potential mechanisms for loss of water from the refueling system exist. These potential leakage paths include reactor vessel head seal leakoff drain lines, neutron detector well covers, transfer canal drains, and steam generator nozzle dams. Procedures are in place to verify that all covers and flanges are bolted in place and that valve line ups are correct prior to flooding the refueling cavity. When steam generator nozzle dams are used during refueling, Procedure PCS-M-42, Revision 1, "S.G. Hot Leg Inspection and Repair", requires that redundant strut support brackets (two out of three) be installed prior to flooding. It was determined that none of these potential leak paths would lead to a catastrophic failure resulting in water uncovering stored fue It is concluded that the issue of loss of refueling system water is adequately resolve No violations or deviations were identifie . _ Reactor Coolant System (RCS) Leak Rate Surveillance Review The inspector reviewed Procedure GOP-13, Revision 1, " Primary System Leakage Calculations", to ensure that acceptance criteria were specified, calculation techniques used by the licensee were adequate for determining RCS leak rate, and leak rate results were adequately evaluated and met acceptance criteria. RCS leak rate results calculated by the licensee following Procedure G0P-13 were below the one GPM requirement of Technical Specification 3.1.5 and compared favorably with results obtained by the

,

inspector using the NRC RCSLR9 computer progra The licensee has experienced some difficulties recently in meeting the one GPM RCS leak rate limit. The inspector noted no problems in the method used to calculate the leak rate but in a review of data from both accepteble and unacceptable tests it appears that the unacceptable tests involved larger inventory changes for RCS make up and letdown. During a

, review of other licensee RCS leak rate results the inspector also noted that many licensees try to keep plant parameters as static as possible during the test period and limit the test period to four hours when possible. The licensee may consider some of these techniques for future RCS leak rate test No violations or deviations were identifie . Refueling Preparations The inspector reviewed training records of personnel assigned to perform refueling operations which are accomplished by reactor operators. The licensee has no formal training progran for fuel handlers other than that which is covered in the qualification and requalification program for the

.

.. .

.

reactor operators. Just prior to commencing core alterations personnel assigned to operate fuel handling equipment perform grappling and ungrappling exercises on a mock-up to refamiliarize themselves with equipment operation. Since extensive modifications were being made to the fuel handling. equipment, the system engineer planned to brief operators on the extent and significance of the modification The inspector also_ reviewed the refueling equipment operational check cut program and observed some of the equipment maintenance activitie The licensee categorized equipment problems from previous refuelings to assist in developing the current maintenance program in an attempt to identify and correct potential equipment problem areas. The success of the program may not be known for several refueling cycles but is considered by the inspector to be a valuable tool for improving equipment performanc During observation of equipment mainteilance activities the inspector noted poor cleanliness controls and observed hand tools being used over the open reactor vessel and SFP area without some means of captivatio Binoculars were used extensively over the reactor vessel during instal-lation of the underwater camera without taking advantage of the installed restraining strap. This condition was brought to the attention of

- licensee management. The licensee stated that they noted similar conditions and activities and had discussed the problem with appropriate maintenance supervision. A previous inspection report (255/85024-(DRP)),

identified a similar problem of using unsecured tools over the SF The day after the inspector discussed the problem of using unsecured tools over the reactor vessel and SFP and the licensee taking action to correct the problem a flashlight was dropped into the SFP tilt pit area when being used without a securing lanyar Procedure requirements are in place which state that, "All loose hand tools, while in use over the reactor or fuel pool, shall be captured,"

as covered in the following documents: S0P-28, Revision 6, Fuel Handling System FHS0-2, Revision 8, Refueling Procedure These procedures were not being followed after repeated identification of the problem. Failure of the licensee to follow refueling procedures as required by Technical Specification 6.8.1 is a violation (255/85031-01(DRS)).

Tests on systems to be used and operable during core alterations were checked by the inspector and verified complete within the time required by review of the following documents: R0-30, Revision 8, Refueling Containment High Radiation Monitor Functional Tes ,

.,. ,

,

. .

l 1 M0-37, Revision 0, Fuel Handling Area Ventilation Syste Technical Specification Procedure RI-86E, Revision 0, Area Monitoring Calibratio Technical Specification Surveillance MC-110, Revision 24, Safeguards Boron Sampl The prerequisites required to support core alterations are listed in Procedure GOP-11, Revision 3, " Refueling Operations," General Check List 11.1. Following a review of the items covered in the checklist, the inspector noted that there appeared to be a conflict between certain prerequisite items. For example, item 14 verifies that the Primary Coolant System water level is lowered below the reactor vessel flange and item 28 verifies that the reactor cavity and south tilt pit are filled to the normal refueling level. Item 15 verifies that the reactor vessel head is sitting on shims for removal and item 16 verifies that the head is removed. The licensee stated that the prerequisite check list is used to aid in sequencing work activities as certain prerequisite items must be complete before certain core alteration preparation activities can commence; however, the procedure provides no guidance as to which prerequisite items must be completed before a particular refueling preparation activity should be allowed to begin, only that prior to starting core alteraticns all prerequisite items must have been verified complete at some time during the refueling preparation phas The inspector recognizes the importance of prerequisite check lists and considers that the procedure which implements them should be clear and precise as to which prerequisites support which work activity. The licensee stated that they were aware of this condition with the prerequisite check list and plan to review General Check List 11.1 prior to the next refuelin The licensee conducted a core reload safety evaluation in accordance with 10 CFR 50.59 and verified that Technical Specification changes are not required for operation during cycle seven. The review concluded that no unreviewed safety questions are involve No-other violations or deviations were identifie . Refueling Activities No fuel handling operations were conducted during the inspection perio The inspector was able to observe handling of the Reactor Light Ring assembly which is used to provide lighting in the reactor vessel during core alterations. Movement of the licht ring consisted of rigging the ring from its storage location on one side of the Containment Building to a work area on the opposite side of the reactor vessel. The move was handled safely in accordance with Procedure FHS-M-24, Revision 4, Movement of Heavy Loads in the Containment Building Area. The required approvals were obtained prior to making the lift and lif ting equipment met procedure requirement m

,

. '.~ '. "; %

Status Boards were set up in the Control Room identifying the current location of core components in the reactor vessel and SF Periodic surveillances were being maintained for SRM and ARM operability, SFP water level, and reactor coolant boron concentratio No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)

on December 20, 1985, to discuss the scope and findings of the inspectio The licensee acknowledged the statements made by the inspector with respect to items discussed in the report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents / processes as proprietar e .

ll U,