ML20203K801
| ML20203K801 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/22/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8605010045 | |
| Download: ML20203K801 (6) | |
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Nwirer beensmg Generet Offices. 1945 West Pernali Road, Jackson, MI 49201. (517) 788 1636 January 22, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT --
RESPONSE TO IE INSPECTION REPORT 85-027 Three items of noncompliance were identified in Inspection Report 50-255/85-027 dated December 23, 1985.
In addition to the items of noncompliance, the cover letter to the inspection, report requested that our response also address an unresolved item from a bovember 8, 1985 event involving a concurrently inoperable Safety Injection Tank and Low Pressure l
Safety Injection Pump. The following is our response to the items of noncompliance and the additional unresolved item:
Noncompliance Item 1:
I As required by 10CFR50.49 and as stated in Consumers Power Company's letter dated November 30, 1984, eight thermostats related to the Safeguards Equipment Room air coolers were to have qualified replacements installed by March 31, 1985.
Contrary to the above, the licensee determined on September 9, 1985, that the planned modification work to install qualified replacement thermostats had not been completed.
Response
Corrective Action Taken And Results Achieved Evaluation of the occurrence determined that the specific responsibility to comply with the commitment to install qualified Engineered Safeguards Room temperature switches by March 31, 1985, or to provide the NRC with an f
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05000255 PDR JAN 2 M OC0186-0012-NLO4 i\\
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J G Keppler, Administrator 2
Palisades Plant Response to IElR 85-027 January 22, 1986 extension request in advance, if the commitment date could not be met, had not been assigned to anyone. The error occurred as a result of a transfer of responsibility for the temperature switches from an engineering projects group to a plant department.
The switches have been replaced. The Environmental Qualification Equipment List was reviewed to ensure that all equipment was qualified by March 31, 1985, identified to be qualified and replaced during our current refueling outage, and was addressed by an appropriate extension request. The use of official scope changes was reviewed with the involved departments to ensure proper transfer of project responsibility.
Corrective Action To Be Taken To Avoid Further Noncompliance, All corrective actions are complete.
Date When Full Cocpliance Will Be Achieved Full compliance has been achieved.
Noncompliance Item 2:
10CFR50, Appendix B, Criterion XVI states in part:
" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." Nuclear Operations Department QA Standard QO-1 " Corrective Action and Control of Nonconforming Items" requires that an Event Report be initiated for potential violations of the Technical Specifications (Section 5.3.1), that the Event Report be reviewed by the Corrective Action Review Board (CARB) within one working day (Section 5.2.4), and a determination made if immediate corrective action is required. Technical Specification 4.17.2 requires monthly verification of valve position and annual stroking of each testable valve in the flowpath for the fire suppression water system. Administrative Procedure 9.23 " Technical Specification Surveillance Procedure Implementation and Corrective Action" requires that action be taken to complete a missed test as soon as possible (Section 6.7).
Contrary to the above, an audit of fire protection conducted September 30 through October 4, 1985, resulted in a finding that a fire suppression water system valve was not being checked as required by Technical Specification 4.17.2.
Action was not taken to test the valve until the evening of November 1, 1985.
OC0186-0012-NLO4
l J G Keppler, Administrator 3
Palisades Plant Response to IEIR 85-027 January 22, 1986
Response
Corrective Action Taken And Results Achieved The occurrence was reviewed with all appropriate plant personnel. The need to provide timely corrective action for significant events was emphasized.
The occurrence was reviewed with the appropriate audit section personnel. The need to promptly screen audit findings for potential immediate corrective action report ie. Event Report initiation was discussed.
Plant procedures currently provide adequate guidance to cause timely corrective action for significant events. The review of this occurrence with personnel will ensure compliance with the procedural requirements.
Corrective Action To Be Taken To Avoid Further Noncompliance All corrective actions are complete.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Noncompliance Item 3:
10CFR50.54(m)(2)(iii) states: "When a nuclear power unit is in an operational mode other than cold shutdown or refueling, as defined by the unit's Technical Specifications, each licensee shall have a person holding a Senior Operator License for the nuclear power unit in the Control Room at all times.
In addition to this senior operator, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times."
1 Contrary to the above, on October 9, 1985, at about 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br /> no licensed Senior Reactor Operator was present in the Control Room for about a five minute period.
Response
Corrective Action Taken And Results Achieved The occurrence resulted f rom a personnel error.
Both Senior Reactor Operators thought they received an acknowledgement before leaving the Control Room. The error was determined to be an isolated occurrence. There have been no similar errors in past operations. This item has been reviewed with the involved personnel.
OC0186-0012-NLO4
J G Keppler, Administrator 4
Palisades Plant Response to IEIR 85-027 January 22, 1986 Corrective Action To Be Taken To Avoid Further Noncompliance All corrective actions are complete.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Additional Items:
The cover letter to this inspection report noted an additional concern with respect to a November 8, 1985, event involving a concurrently inoperable Safety Injection Tank and Low Pressure Safety injection rump. Certain operator errors were also identified. A response and, as appropriate, an outline and schedule for corrective actions were requested for the following issues:
- 1) With known leakage into the SITS and a history of prior problems, no action was taken to anticipato the amount of dilution which could be tolerated before the concentration of boron fell below the T.S. limit (the PCS boron concentration was at 94 ppm).
- 2) The level indicator and administrative alarms for the SIT were not functional and did not warn the operator he was approaching a T.S. limit.
Inoperability of these indicators and alarms have been contributors to prior events of SIT inoperability.
- 3) The operators conducted feed and bleed operations to increase the concentration, but after the first cycle the SIT concentration dropped fron 1708 to 1548 ppm.
- 4) The operators did not recognize that they already had an Emergency Core Cooling Component inoperable and conducted feed and bleed by filling above the high level limit and draining below the low level limit which was in violation of the Technical Specifications.
- 5) The Shift Supervisor and Shift Engineer did not recognize that a condition existed which exceeded the allowable conditions of their T.S. until about four hours into the event.
- 6) Corrective maintenance completed during the previous outage was not successful in preventing loop check, fill and drain and pressure control valve leakages.
Response
Primary Coolant System leakage to the Safety injection Tanks has been a continuing problem that has resulted in a high degree of management attention and large expenditures of time and resources. The impact of this leakage on OC0186-0012-NLO4
l J G Keppler, Administrator 5
Palisades Plant Response to IEIR 85-027 January 22, 1986
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power production is readily apparent and, in itself, is sufficient to ensure our commitment to resolve this problem.
As noted, corrective maintenance completed during the previous outage was not fully successful in preventing the leakage. Malfunctions in the level indication system for the tanks were also noted. We are currently repairing all valves suspected of leakage. These repairs will be completed during the present refueling outage. The level indication problems resulted from a combination of the leakage problem and the design of the level transmitters.
This design will be modified in the 1987 refueling outage.
It should be noted that the level indication system functions properly when leakage from the coolant system is not excessive. Therefore, irmediate modification to this indication system is considered unnecessacy.
To ensure a complete and thorough evaluation, a systems expert from Combustion Engineering conducted a review of our activities to date.
The review included items such as system and component design, maintenance procedures and operating practices.
As a result, certain improvements to corrective maintenance procedures were applied to the recent repairs.
Recommendations to j
improve the system operation are being evaluated for utilization in operating procedures. These recommendations included a change in the mode of operation of the system such that the fill and drain lines remain depressurized, and a change in the method of restoring level in the safety injection tank such that the affect on boron concentration in the tank. is minimized.
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Prior to November of 1985 in the current production period, the frequency of inoperable Safety Injection Tanks was limited.
This would indicate that the repairs performed in the prior refueling outage were moderately successful.
In June of 1985 following a low boron occurrence, controls were under consideration to aid in preventing boron dilutions below Technical l
Specification requirements. These controls included such things as l
implementing an administrative requirement to have final boron concentration in the Safety Injection Tank above 1790 ppm af ter boron concentration adjustment and also to increase boron sampling frequency for the Safety Injection Tanks.
Subsequent review, approximately one month later, determined l
that the lack of any recurrence of a problem was sufficient to waive the imposition of these controls.
In November of 1985, the occurrence of l
inoperable tanks from leakage suddenly increased. Again, additional controls were considered. However, prior to implementation, the plant entered the current refueling outage.
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The occurrence of a boron dilution in the Saferv Injection Tank during a drain and fill evolution resulted from the leakage of very low boron concentration primary coolant into the drain and fill lines.
The reduction in concentration was not considered significant since the tank was previously inoperable and a satisfactory sample is required before operability is restored. The repairs to be performed for the valves sospected of leakage will prevent any recurrence of this type of di1'trinn.
OC0186-0012-NLO4 l
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J G Keppler, Administrator 6
Palisades Plant Response to IEIR 85-027 January 22, 1986 The operator errors noted during this occurrence were reported as part of Licensee Event Report 85-024. We recognize the potential significance of this type of error and have reviewed the event with all Senior Operators. The necessity to thoroughly evaluate the effect of equipment operability on Technical Specification requirements was emphasized.
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Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcenent NRC Pesident Inspector - Palisades OC0186-0012-NLO4