05000255/LER-1997-013, :on 971110,determined Check Valves in Min Flow Recirculation Piping from Discharge of Each HPSI Pump Were Not Periodically Tested to Confirm Closure Capability.Caused by Inadequate Understanding.Database Revised
| ML20217A286 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/15/1998 |
| From: | Flenner P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18068A328 | List: |
| References | |
| LER-97-013, LER-97-13, NUDOCS 9804220224 | |
| Download: ML20217A286 (11) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function |
| 2551997013R00 - NRC Website | |
text
-
NRC FORM 366 U.S. NUCLEAR REOULATORY COMMISSION APPRC,VED BY 0".B NO. 3150-0104 (4/95)
EXPlRES 4/30/98
'J==TcTab"!Jat.%'=ITs* 4=,"4 LICENSEE EVENT REPORT (LER) lat,=c^=J;n==g*** m #fr a L P$'4"
=ss*,c[S*^To'NIc"aowEoi[ETo"nE PAPER R
(See reverse for required number of digits / characters for each block)
PRomet pisO@04 CWCE CF MMeAGEMENT AND BUDGET. WA8m3ToK Dc 2M03 re.ciuTY N4ME (1) CONSUMERS ENERGY COMPANY MCKET NUMBER (2)
Page (3) l PALISADES NUCLEAR PLANT 05000255 3 of 3 3
[
TITLE (4) SUPPLEMENT 1, ' VIOLATION OF TECHNICAL SPECIFICATION 6.5.7 FOR FAILURE TO FULLY I
TEST VALVES" l
EVENT DATE (5)
LER NUMBER (6)
REPORT DATE (7)
OTHER FACILITIES INVOLVED (8)
SEQUE IAL REV Si OME "
MONTH DAY YEAR YEAR MONTH DAY YEAR ER 05000 FAwTY NAME DOCKET 11 10 97 97 013 01 4
15 98 l
95 0 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR$: (Check one or more)(11)
MODE (9)
N 20.2201(b) 20.2203(a)(2)(v)
X 50.73(a)(2)(i) 50.73(a)(2)(iii)
POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50 73(a)(2)(ii) 50.73(a)(2)(x)
LEVEL (10) 99.6 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv)
OTHER 20.2203(a)(2)(in) 50.36(c)(1) 50.73(a)(2)(v)
Specify in Abstract below 20 2203(a)(2)(#v) 50.36(c)(2) 50 73(a)(2)(vii) or in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)
NAME Philip D. Flenner, Licensing Engineer TELEPHONE NUMBER (include Area Code)
(616) 764-2544 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)
CAUSE
SYSTEM COMPONENT MANUFACTURER REPORTABLE
CAUSE
SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS SUPPLEMENTAL REPORT EXPECTED (14)
MONTH DAY YEAR YES NO EXPECTED If yes. COMPLETE EXPECTED COMPLETION DATE X
SUBMISSION DATE (15)
ABSTRACT (Limit to 1400 spaces. i.e., approximately 15 single-spaced typewritten lines) (16)
On November 10,1997, the plant was operating at 99.6% power. During the evaluation of an NRC Architect-Engineering Design Inspection team request for information, it was determined the check valves (CK-ES3339 and CK-ES3340) in the minimum flow recirculation piping from the discharge of each High Pressure Safety injection (HPSI) pump were not periodically tested to confirm their closure capability. It was concluded that this is contrary to the requirements of ASME XI and Technical Specification 6.5.7.
A review of other check valves, control valves, and motor operated valves for similar testing i
discrepancies identified four additional instances where valves were not fully tested. These four I
instances are reported in this supplement.
I In each case, upon discovery, the equipment was either declared inoperable until testing was I
ptrformed or determined to be operable per ASME Code or Technical Specifications requirements.
I All affected valves which were declared inoperable were subsequently tested and were declared I
operable based on the results, within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period allowed by Technical Specification 4.0.3.
I 9804220224 980415 PDR ADOCK 05000255 S
NRC FORM 364a U.S. NUCLEAR REGULATORY CoMMIS$10N 4,95 1
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME M)
DOCKETf2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SE UE L
R S N PALISADES NUCLEAR PLANT 05000255 2 oF 11 97 013 01 TEXT (if more space is required, use additional copies of NRC Form 366A) (17)
EVENT DESCRIPTION
On November 10,1997, the plant was operating at 99.6% power. During the evaluation of an NRC Architect-Engineering Design Inspection team request for information, it was determined the check valves (CK-ES3339 and CK-ES3340) in the minimum flow recirculation piping from the discharge of each High Pressure Safety injection (HPSI) pump were not periodically tested to confirm their closure capability. It was concluded that this is contrary to the requirements of ASME
{
Section XI and Technical Specification (TS) 6.5.7. The requirements for valve testing are I
contained in ASME Section XI, Article IWV, which references OMa-1988 (Part 10). OMa-1988 I
(Part 10), Section 4.3, specifies the Inservice Testing (IST) requirements for Category C check I
valves. The technical concern is an interface between a high pressure and low pressure system I
not being tested periodically to confirm appropriate isolation. Without such confirmation of I
isolation, it is postulated that the piping and components with lower pressure rating might be overpressurized. Although these check valves were not being tested periodically for the closure attribute, they were being tested regularly for the open attribute per the ASME Section XI valve I
testing program. They also were included in the Check Valve Program which had confirmed the satisfactory matcriel condition of these valves.
Upon discovery, both HPSI pumps and associated check valves were declared inoperable. TS I
4.0.3 allows for a delay up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the surveillance testing prior to taking the I
required TS action. The check valves were tested to confirm they would close properly. The HPSI I
pumps and associated components were declared operable and compliance with the TS was I
restored. The testing was performed without any reduction in plant power level.
A review of other check valves, control valves, and motor operated valves for similar testing I
discrepancies was undertaken to determine if similar problems were present. This review I
identified four additional instances where valves were not fully tested. These four instances are:
I I
(1). Check valve CK-DMW400 has a function to open and pass water flow from Primary Makeup I
Water Tank T-81 to Condensate Water Storage Tank T-2. The function was not being I
periodically tested. This condition was identified on March 17,1998 with the plant at full I
power. The check valve was declared inoperable. Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the valve was I
declared inoperable, a non-intrusive accoustical test was performed while subjecting the I
check valve to a flow condition and the test successfully confirmed the valve would open. On I
this basis, the valve was declared operable. No mode changes or power reductions were I
required relative to this testing.
I i
.U.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUENTIAL REVISION NW8ER NWBER PALISADES NUCLEAR PLANT 0500025s 3 oF 11 97 013 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
(2)
Charging Pump Line to Safety injection Test Line Isolation Valve MO-3072 has a remote I
position indication which has not been tested to verify that the valve position is properly I
indicated. This condition was identified on March 17,1998 with the plant at full power.
I l
MO-3072 is a normally closed valve with a closed safety function and no open safety I
i function. MO-3072 was determined to be operable because the valve was verified to be I
j closed and therefore met its safety function. This is not considered to be a reportable i
condition but is included as an instance where the IST Program was deficient.
I 1
(3)
Air Space Purge Fan V-46 Discharge isolation Valves CV-1813 and CV-1814, which are I
)
electrically locked closed in power operation but can be opened in cold shutdown, were not 1
J timed during stroke testing. This condition was identified on March 17,1998, with the plant i
1 at full power. CV-1813 and CV-1814 were determined to be operable since they were I
electrically locked closed in their safety function position, as required by TS. However, these I
valves were caution tagged to remain closed until their stroke-to-close time is tested.
I I
I (4)
Containment Steam Heating Return and Supply Valves CV-1501, CV-1502, and CV-1503 I
were not timed during stroke testing. This condition was identified on March 26,1998 with i
1 the plant at 90% of full power. These valves were declared inoperable. They were timed I
during stroke testing within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and declared operable after successful testing.
I
ANALYSIS OF EVENT
The general commitment to an inservice testing program per ASME XI is contained in TS 6.5.7.
I TS 6.5.7 however does not provide system or component testing requirements. Identifying l
components for inclusion in the ASME XI testing scope depends on the plant specific design basis.
The IST program documents EM-09-02, " Inservice Testing of Plant Valves," and EGAD-EP-09, I
" Palisades inservice Testing Program Basis Document," consist of a component-by-component I
determination of required performance attributes and the appropriate testing for those attributes. A key input for the IST program is the Palisades Equipment Database. The Palisades Equipment Database was developed through design reviews and identifies safety-related equipment and their required operating modes.
For check valves CK-ES3339 and CK-ES3340, the components have always been considered safety related for pressure retention and they are in an ASME XI Class system. The required 2
operating configurations in the Palisades Equipment Database have been safety related to open, but non-safety related for closure for both valves. This initial Palisades Equipment Database design interpretation was documented in 1979. Based on this determination, these particular valves were included in ASME XI IST testing to confirm they will open, but not included in the ASME XI IST testing to confirm closure.
i
.U.S. NUCLEAR REGULATORY CoMMISSloN 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER HL*MR (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUENTIAL REVISION N M ER N M ER PALISADES NUCLEAR PLANT 05000255 4 op gj 97 013 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
In the late 1980s, a major upgrade to the Palisades IST program occurred. Upgrades for valve 1
testing were based on preliminary Generic Letter 89-04 information. In April 1988, upgrades to EM-09-02 " Inservice Testing of Plant Valves" were completed which included the addition of check valves CK-ES3339 and CK-ES3340 to the scope of the IST program. These check valves were I
only specified to be tested to confirm they would open per surveillance test QO-19 "HPSI Pumps and ESS Check Valve Operability Test". An objective of this upgrade to the IST program was to assure that required attributes identified in the Palisades Equipment Database were incorporated
{
into the IST program. The upgrade was not intended to validate or reconstruct the plant's design basis. Therefore, the existing Palisades Equipment Database was used as the basis for I
determining valve test requirements. Since the Palisades Equipment Database only specified an I
open safety function, the closed safety function was not specified as requiring a test. Had the 1
valves been identified in the Palisades Equipment Database as having a closed safety function, there would have been an IST test to periodically confirm proper closure.
Review actions, initiated as a result of the original event, identified additional valves which were I
not being tested as required. The causes were similar to that determined for the failure to perform I
the proper inservice tests on check valves CK-ES3339 and CK-ES3340. Errors in the Equipment I
Database or in the use of the Equipment Database led to the failure to properly test the identified I
valves within the IST Program. Following are discussions of the causes that led to inadequate I
testing for the additional valves:
I I
(1)
Check valve CK-DMW400 has a safety function to open and pass water flow from Primary 1
Makeup Water Tank T-81 to Condensate Water Storage Tank T-2. The Equipment i
Database incorrectly identified the open position as non safety-related. This led to the failure I
to include valve testing to verify the function to open.
I I
(2)
Charging Pump Line to Safety injection Test Line Isolation Valve MO-3072 has a passive I
safety function to remain closed. Although the closed safety position of the valve can be and I
has been verified, a position indication check is required. Although the Equipment Database I
correctly identified the closed, passive safety function as safety-related, an action was taken I
in error to remove the valve from the surveillance testing procedure. This was caused by an I
inadequate consideration of all the available details when determining the IST scope and I
testing requirements.
I I
(3)
Air Space Purge Fan V-46 Discharge isolation Valves CV-1813 and CV-1814 have a passive I
safety function to remain closed during any postulated accident occurring above cold I
shutdown operation. These valves are electrically locked closed above cold shutdown in I
accordance with the Technical Specifications and therefore are capable of performing their I
safety function.
I
NRC FORM 344a U.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY WR SE M ENTML REVISION NWBER N M ER PALISADES NUCLEAR PLANT 05000255 5 oF 11 97 013 01 J
TEXT (If more space is required, use additional copies of NRC Form 366A) (17) f During cold shutdown, CV-1813 and CV-1814 may be open to provide a flow path for Air I
Space Purge Fan V-46 to containment. The valves would be required to close on a I
j Containment High Radiation (CHR) signal. In this case, they would have an active safety I
function to close. However, since containment isolation is not assumed during the postulated I
fuel handling accident in FSAR 14.19, no credit is taken for closure of the valves and the I
active safety function to close was not included in the IST Program.
I I
When the IST Program was updated for the Third Interval in 1995, Palisades failed to add I
these valves for position indication testing; which is required for passive valves by ASME XI.
l This was caused by an inadequate consideration of all the available details when i
determining the IST scope for these valves. Prior to that update, the code did not require i
position indication testing for a passive function and therefore the valves were not included in I
the program.
I I
(4)
Containment Steam Heating Return and Supply Valves CV-1501, CV-1502, and CV-1503 I
have a safety function to remain closed during any postulated accident occurring above cold I
shutdown operation. During this mode of operation, the normally closed valves are not I
locked closed and therefore have an active safety function to close if either a Containment I
High Pressure or a CHR signalis received. The valves were not included in the IST Program I
as having an active safety function to close since they are normally closed and are seldom I
used.
I
.I During cold shutdown, CV-1501, CV-1502, and CV-1503 may be open to provide heating to I
containment if needed. The valves would be required to close on a CHR signal in this case, I
the valves would have an active safety function to close. However, since the containment I
isolation is not assumed during the postulated fuel handling accident in FSAR 14.19, no I
credit is taken for closure of the valves and the active safety function to close was not I
included in the IST Program.
I I
i When the IST Program was updated for the Third Interval in 1995, Palisades failed to test I
the valves for either stroke time or position indication. This was caused by an inadequate I
consideration of all the available details when determining the IST scope for these valves.
I I
Palisades has considered the extent of this event. Due to the extensive validation over recent I
years in other Engineering Program areas, we believe that these types of problems do not exist I
beyond the ISI/IST area. Consequently, the ISI Program basis document will be reviewed and I
upgraded to a plant procedure. This process will include reviews which will serve to identify if ISI I
Program deficiencies similar to those identified in the IST Program exist.
I
- ~
.u.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY '
05000255 6 oF 11 YEAR SEQUENTIAL REV SiON Pall 3ADES NUCLEAR PLANT 97 013 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
SAFETY SIGNIFICANCE
The overall safety significance of this event is low. This conclusion is based on the functions of I
the valves identified and the subsequent analyses or testing which occurred to verify the operability I of the valves. The following provides details for the specific valves identified:
I l
- - Check valves CK-ES3339 and CK-ES3340 1
The following postulated scenario creates a potential overpressurization in the HPSI suction piping if the check valves leak. Note that either HPSI pump could apply in this scenario. The case of HPSI pump, P-66A, operating and HPSI pump, P-66B, idled will be described, see the attached sketch. This postulated scenario presumes two in-series check valves stick-open, while the check I
valve on the suction of the idle HPSI pump closes. The check valves in the common header to the i
Safety injection Refueling Water (SIRW) Tank (CK-ES3331 and CK-ES3332) are extra valves which are not credited with preventing backwards flow, but which are tested to assure they allow normal flow.
The scenario involves a post-accident lineup which occurs after recirculation actuation signal conditions, one HPSI pump running and supplying water to the Primary Coolant System (PCS), the I
other HPSI pump turned off, and PCS pressure just below the shut off head of the HPSI pumps.
I The minimum flow recirculation flow path to the SIRW Tank is isolated by the closure of CV-3027 and CV-3056 due to the recirculation actuation signal. Check valves CK-ES3331 and CK-ES3339 are stuck open (assumed because not previously subjected to periodic IST closure tests), allowing backwards flow and pressure to transmit through the idled HPSI pump, P-66B, to its suction side piping. Check valve CK-ES3168 is closed (assumed because this is confirmed by IST testing) and capable of preventing backwards flow, thereby allowing P-66B suction side piping to be pressurized from the discharge pressure provided by operating HPSI pump P-66A. This check valve backflow leakage scenario results in pressure build up in the idle HPSI pump discharge piping untilit would equalize at or near the PCS pressure, and in the HPSI suction piping which is I
potentially subjected to pressure exceeding its design rating of 500 psig. Thus, there exists a possibility of overstressing the piping by applying pump pressure and this makes the closure I
attribute a safety related function for these check valves.
In recognition of the importance of these check valves, the IST program has been testing these check valves per ASME XI to confirm they open. In addition, the check valve program has been monitoring these check valves and has confirmed that no degradation of their materiel condition I
has occurred. What was not recognized was the IST requirement to test the closure attribute. The I
testing performed confirms the check valves close satisfactorily and there was no backflow l
.U.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUM9ER (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUEN lAL REVIION PALISADES NUCLEAR PLANT 05000255 7 oF 11 97 013 01 TEXT (if more space is required, use additional copies of NRC Form 3S6A) (17) leakage. Based on the need for multiple failures of in-series components between the discharge I
of the operating HPSI pump and the suction of the idle pump to result in overpressurization, and I
the as-found satisfactory condition of the check valves, it is concluded that minimal risk of overpressurizing the HPSI pump suction piping existed. Therefore, the safety consequences were minimal for not routinely testing these check valves per ASME XI for the closed safety function.
I Check valve CK-DMW400 l
I Based on satisfactory performance of CK-DMW400 during the immediate action testing, it is I
concluded that there was no degradation of the demineralized water supply to the AFW pumps.
I The past and current capability of providing demineralized water supply flow through this check I
valve has been shown to be adequate.
I I
Additional confirmation that flow through this path meets the flow requirements was provided by I
special test T-344 performed in 1994, which confirmed the required flow of 100,000 gallons of I
water from T-81 and T-2 to the AFW pumps. Additionally, T-2 rNtinely receives makeup from I
tank T-939, " Demineralized Water Storage Tank," via flow through this check valve which further I
confirms that it opens properly.
I I
The safety significance of the failure to perform an IST surveillance test on CK-DMW400 was I
minimal since the safety function of the valve to open has been shown by other means. In I
addition, a nonintrusive accoustical test verified the ability of the valve to open to perform its safety I
function.
I I
Valve MO-3072 I
I MO-3072 is a passive valve and therefore only a position indication check is required. The valve is I
in the sccpe of NRC Generic Letter 89-10 and receives a maintenance condition check every 18 I
months, a staiic VOTES tests every 3 refueling outage cycles, and a differential pressure test I
every 5 refueling outages. The last check was performed on March 20,1997. The intent of the i
IST position indication test is met by the combination of the condition check and the subsequent I
functional stroke test, which successfully verified the operation of the valve.
I I
There was no safety significance of the failure to perform an IST surveillance test on MO-3072.
I I
NRC FORM 346a U.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME 0)
DOCKET (2)
LER hUMBER (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEC OENTIAL REVISION PALISADES NUCLEAR PLANT 05000255 8 oF 11 97 013 01
)
TEXT (if more space is required, use additional copies of NRC Form 366A) (17)
Valves CV-1813 and CV-1814 I
I CV-1813 and CV-1814 are position indication tested once each refueling outage per SOP-3, I
" Safety injection and Shutdown Cooling System," Checklist 3.3, " Containment Integrity I
)
Checklist." Although this testing is not identified in the IST Program, Checklist 3.3 does satisfy I
position indication testing requirements. CV-1813 and CV-1814 are electrically locked closed I
above cold shutdown operations. Locking these valves closed satisfies Technical Specification i
Definition 1.0 of " Containment Integrity" required above cold shutdown operation. CV-1813 and l
CV-1814 are also stroke exercised per RO-30 " Refueling Containment High Radiation (CHR) l Monitor Functional Test." This Technical Specification Surveillance Procedure tests CHR isolation I
by exposing the High Radiation Monitors to a source above their set points and verifying the I
I corresponding equipment responds per design.
I I
The safety significance of the failure to perform IST surveillance tests on CV-1813 and CV-1814 1
3 was minimal. The position verification check and stroke exercising are both being performed 1
J during other tests although stroke timing is not performed. Valves CV-1813 and CV-1814 have I
been shown to be capable of providing their safety functions.
I I
Valves CV-1501. CV-1502. and CV-1503 I
I CV-1501, CV-1502, and CV-1503 are active valves with a closed safety function. These valves l
l normally remain closed above cold shutdown operations, except when they are tested per I
Technical Specification Test Procedure QO-5, " Valve Test Procedure (Includes Containment I
isolation Valves)," to verify they are capable of stroking from open to closed. Upon discovery of I
the lack of stroke time testing, CV-1501, CV-1502, and CV-1503 were tested and confirmed to be I
capable of stroking from open to close in much less than 25 seconds.
I I
The safety significance of the failure to perform IST stroke timing surveillance tests on CV-1501, I
CV-1502, and CV-1503 (which are normally closed) was minimal. After discovery of the event, I
these valves were stroke time tested and successfully demonstrated the capability to perform their I
safety function.
I
4U.S. NUCLEAR REGULATORY COMMISSloN 4/95 LICENSEE EVENT REPORT (LER)
TEXT CoNTINUATloN FACILITY NAME (1)
DOCKET (2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY a
seygegm aggos9 PALISADES NUCLEAR PLANT 05000255 9 oF 11 97 013 01 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
CAUSE OF THE EVENT
The following deficiencies contributed to the cause of this event:
1 I
(1)
Inaccurate information or inadequate level of detail available in selected design basis I
information, including the Equipment Data Base, have led to errors in determining testing i
requirements, I
I (2)
The IST Basis and the scoping documents were inadequate as a result of a lack of a I
technical review to verify component functions and testing requirements, I
I (3)
Palisades had an inadequate understanding and failed to consider all of the available details I
when determining the IST scope and testing requirements.
i CORRECTIVE ACTIONS COMPLETED (1)
The check valves CK-ES3339 and CK-ES3340 were tested to confirm proper closure I
capability.
I (2)
Check valve CK-DMW400 was tested to confirm the proper opening capability. Additionally, I
other test results were used to verify the capability of the valve to perform its safety function.
I I
(3)
Isolation valve MO-3072 was determined operable since a closed position verification was I
performed. In addition, MO-3072 was tested on April 12,1998.
1 I
(4)
Isolation valves CV-1813 and CV-1814 were determined operable since they are electrically I
locked in the closed safety position above cold shutdown operation.
I I
(5)
Return and Supply valves CV-1501, CV-1502, and CV-1503 were stroke time tested to I
confirm the proper closing capability.
i I
(6)
Palisades Equipment Database safety related interpretations for the check valves I
(CK-ES3339 and CK-ES3340) were revised. In turn, the Palisades Equipment Database I
was revised accordingly, and the closure attribute of the check valves was added to the l
Inservice Testing program.
I I
(7)
Other ASME Section XI check valves, control valves, and motor operated valves were i
reviewed for similar discrepancies in their Palisades Equipment Database or testing scope.
I Palisades Equipment Database interpretations and procedure changes were initiated to I
4 IU.S. NUCLEAR REGULATORY COMMISSION T
4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER (6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUENTIAL REVISION WMBER WMBER PALISADES NUCLEAR PLANT 05000255 10 0F 11 97 013 01 TEXT (if more space is required, use additional copies of NRC Form 366A) (17) correct the discrepancies and to ensure that future testing requirements are met. By I
completing this action, an improved understanding for the IST scope and testing I
requirements was gained.
I a
I (8)
The Palisades Engineering Programs Staff have been briefed regarding this event and the I
need to verify the information gained from the Palisades Equipment Database.
I CORRECTIVE ACTIONS TO BE COMPLETED The following actions will be completed:
(1)
Revise the Palisades Equipment Database and IST Basis Documents for the affected valves.
1 I
(2)
Complete a documented review of the ISI basis document to determine if similar conditions i
exist within the ISI Program, as were identified in the IST Program.
I I
(3)
The remaining Engineering staff will be informed of this event with the need to verify i
Engineering Database information.
I
6U.S. NUCLEAR REGULATORY COMMISSION 4/95 LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACILITY NAME (1)
DOCKET (2)
LER NUMBER '6)
PAGE CONSUMERS ENERGY COMPANY YEAR SEQUENTML REVISION NUMBER NUMBER PALISADES NUCLEAR PLANT osooc2ss gg gp $$
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