IR 05000255/1994020
| ML18064A473 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/04/1994 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18064A472 | List: |
| References | |
| 50-255-94-20-EC, EA-94-222, NUDOCS 9411220005 | |
| Download: ML18064A473 (32) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report N ~55/94020 Docket No. 50-255 Licensee:
Consumers Power Company 212 We~t Michigan Avenue*
Jackson, MI 49201 Meeting Conducted:
November l, 1994 Meeting At:
Region III Office, Lisle, Illinois Type of Meetin~: Enforcement Conference License No. DPR-2 EA 94-222 Inspection Conducted:
Onsite at P~lisades Nuclear Plant, August 30 through October 12, 199~_
Inspectors:
M. Parker Approved By:
Senior Resident Inspector D. Passehl Resident In pector W. J. Kropp, Chief Reactor P~ojects Section 2A Meeting Summary Date Enforcement Conference on November l, 1994, (Report No. 50-255/94020)
Areas Discussed:
The apparent violations and areas of concern regarding the inability of th~ diesel generators to fully supply maximum analyzed electrical power during a postulated design basis accident were reviewe The corrective actions taken or planned by the licensee were also discusse PDR ADOCK 05000255 a
- DETAILS Persons Present at Conference R. Fene~h, Vice Pre~ident, Nuclear Operation~
T. J. Palmisano, Plant General Manager K. P. Powers, Engineering Programs Manager K. M. Haas, Safety and Licensing Director.
R. N. Swanson, Director, Nuclear Performance Assessment Department K.' A. Toner, Design Engineering Manager D. G. Malone, Shift Operations Superintendeht R. Ai Vincent; Licensing Administrator T. C. Duffy, Safety Analysis Supervisor L. D. Seamans, Configuration Management Supervisor M. D. Bourassa, Licensing Supervisor K. E. Yeager, Electrical Engineering Supervisor D. J. VandeWalle, System Engineering Manager P. J. Gir~, Licensing Engineer G. Szczypka, System Engineer D. A; McKee, Senior Public Information Specialist U. S. Nuclear Regulatory Commission. Region III
- J. B. Martin, Regional Administrator, Riii R. w. Defayette, Director, Enforcement and Invest. Coord. Staff, Riii
- E. G: Greenman, Director, Division of Reactor Projects, Riii J. N. Hannon, Project Director, NRR P. R. Pe1ke, Enfortement Specialist, Rill M. A. Satorius, Enforcement Specialist, NRR B. A. Berson, Regional Consul, Riii
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W. J. Kropp, Section Chief, Riii M. K. Gamberoni, Project Manager, NRR C. N. Orsini, Reactor Engineer, Riii R. M. Lerch, Reactor Engineer, RIII D. S. Butler, Reactor Inspector, Rill M. S. Holmberg, Reactor Inspector, RIII M. E. Parker, Senior Resident Inspector, Palisades Nuclear Plant D. Passehl, Residerit Inspector, Palisades Nuclear Plant Enforcement Conference An Enforcement Conference was held in the NRC Region III office on November l, 1994. This conference was ~onducted as a result of the*
preliminary findings of the inspection conducted from August 30 through October 12, 1994, in which apparent violations of NRC regulations and license conditions were identified. Inspection findings are documented in Inspection Report No. 50-255/94017, transmitted to the licensee by letter dated October 27, 199 The purpose of this conference was to (1) discuss the apparent violations, causes, and the licensee's corrective actions; (2) determine if there were any escalating or mitigating circumstances; and (3) obtain any inform~tion which would help determine the appropriate enforcement actio..
The licensee's representatives did not contest any of the apparent violations and were in agreement with the NRC's understanding of the areas of concer.
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The licensee's representatives described the e~ents which led to the apparent violations, incl~ding root causes and corrective actions taken and planne A summary of the licensee's corrective actions is included in the attached handout that the licensee provided at the conference (Attachment 1).
Included among these were actions taken or planned in the areas of control of maintenance; design and test control; control of vendor data and recommendations; and management standards and. *
organizatio The lic~risee's plans appeared comprehensive and indicated a thorough appreciation for the significance of the events that had taken place.
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PALISADES*.
NUCLEAR PLANT*
PALISADES-ENFORCE:MENT CONFERENCE DEGRADED DIESEL GENERATOR NOVEMBER 1, 1994
NRC INTRODUCTION CPCO INTRODUCTION.................. RA FENECH PRESENTATION OVERVIEW........... T J. PALMISANO SEQUENCE OF EVENTS............ DJ VANDEWALLE ISSUES-........................ DJ VANDEWALLE
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CONTROL OF MAINTENANCE
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DESIGN AND TEST CONTROL VENDOR DATA AND RECOMMENDATIONS
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MANAGEMENT STANDARDS/ORGANIZATION LESSONS LEARNED FROM RECENT EVENTS GENERIC IMPLICATIONS......... ~..... KP POWERS SAFETY* SIGNIFICANCE......
........... KP POWERS MITIGATING FACTORS.... ~............. KM HAAS NPAD PERFORMANCE................ RN SWANSON *
MANAGEMENT LESSONS LEARNED... *.. T J PALMISANO CLOSING REMARKS................. ~.. *RA FENECH
DATE.<
1969 1971 1979 1980 1982 I
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I Vendor shop test of D/G Pre-operational peak load test Te~h. Spec. requires monthly test at 2,400 KW+/- 100 K DIG 1-1 mechanical governor upgrad Decisiori.to not perform vendor recommended maintenanc D/G 1-1 mechanical governor actuator replacemen SEQUENCE OF EVENTS Tech~ Spec. basis should have captured relationship between SAR and tes Preserve D/G critical characteristic Post-m*a i ntenance tes Review decision with vendor and establish other appropriate preventive/predictiv~
maintenanc Preserve D/G critical characteristic Post-mai~tenance tes Load capability
> 2,800 KW with minor fuel rack travel still ava*il abl *. D/G 1-1 2730 KW D/G 1-2 *2720 KW Design load is 1,970 K No test to verify that engine could still achieve 2,800 K Failed to perform appropriate maintenanc No test to verify that engine could still achieve 2,800 K Design Control Control of Maintenance Vendor Recommendations Management
- standards Control of Maintenance Vendor Recommendations
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- DATE 1984 1986-89 May 1991 Nov 1991 1 Mar 1994 I
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EVENT
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Additional, automatically sequenced loads increase D/G
. design loadings to - 2,500 K.
- ,AFW Pumps
- H2 recombiner Refinements in D/G loading analysis result in loadings
> 2500 K Evaluation of D/G testing criteria concludes th~t peak load testing is not necessary or require EDSFI identifies concerns with D/G loading analysis and testin DET identifies concerns with D/G loading analysi *
SEQUENCE OF EVE"TS Design Control Evaluation of D/G margins Safety Eva 1 ua.t ion Design Control Evaluation of D/G margins Safety Evaluation Evaluation of risks of not performing peak load testin Critical review and test Design Control Safety Evaluation Design Control Safety Evaluation
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Safety Evaluation and evaluation of D/G margins performed in design change proces Change to Tec Specs. not addressed Did not identify required Tech. Spe changes or need to verify D/G design basis load carrying capabilit Risks were not well understoo Tec Spec. basis and GDC-18 not satisfie Did not identify required Tech. Spe changes or need to test Did not identify required Tech. Spe changes or need to tes *
. ISSUES Design Control Design Control Less than adequate QA/PRC oversight Management Standards Design Control Less than adequate QA/PRC oversight Management Standards Design Control Management Standards Design Control Management Standards
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I DATE July 19, 1994 July 29, 1994 August 29, 1994
SEQUENCE OF EVENTS D/G 1-.1 maximum load of 2,340 KW during monthly surveillance tes Engine output met monthly test criteria but operators retognized new issue System Engineer on-site and involved in operability determination. Condition report writte Pe.riodic management briefings commenced on July 20th.
Partial adjustment of D/G 1-1 electrical governor limits. Achieve 2,400 K A complete governor inspection and.a~justment will ~equire further plannin Pl~nty of rack travel* availabl Looking into test at peak design loa Periodic management briefings continued ~nto August Condition report on lack of testing to verify OBA load capability of EDG I
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DATE**
August 30, 1994 August 31, 1994 Sept. I, 1994 *
SEQUENCE OF EVENT~
Adjust EGA Droop, EGB settings and MOP cam Temporary precision' metering used* for KW indicatio For the first time engine output is mech~nically limite Only able to obtairi 31 MM rack trave Declare EOG 1-1 inoperabl Develop troubleshooting team
~ determine shift coverage need Coltec vendor on sit Performance trend graphs review Fuel oil calorimetric analysi Developing full load t~st procedur Adjust two injection pump~.
Replace all fuel injector Fuel rack adjustmen I
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Sept. 2, 1994 Sept. 3, 1994 Sept. 4, 1994 Sept. 5, 1994 SEQUENCE OF EVENTS ililli<{**********
Determine EOG 1-1 inoperable for extended period of tim Condition report writte Replace 3 fuel pump Install new air filter Fuel rack adjustmen Turbocharger inspectio PRC review/approval of special test and engine operability criteri Perform special peak load test, (results 2685 KW)
Adjust gtivernor linkage to fuel
~ac Reperform Special Test. Obtain 2728 K Declare EOG 1-1 o erabl *Management revie~ of past operability determination~.
Review generic implications for O/G 1-Oevelo full 16ad test for 0 G 1 I O'
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Sept. 6, 1994 Sept. 7, 1994 October 7, 1994 SEQUENCE OF EVENTS Test _O/G l"'.2 and obtain rack p'osition measuremen PRC revie~/approval of special test and operability criteri Peak design load test for D/G 1-2 initially fails by 13 KW, 2665 vs. 2678 K Adjustments to governor linkage, control linkage hardstop and fuel pumps result in acceptable test second ti~ *
Condition re ort written on D G 1-2 ino Complete D/G root cause evaluatio October 11, 1994 Oversite by independent nuclear safety exper NOVEMBER 1; 1994 ENFORCEMENT CONFERENCE PALISADES DIESEL GENERATORS ISSUES CONTROL OF MAINTENANCE
. DESIGN AND TEST CONTRO VENDOR DATA AND RECOMMENDATIONS MANAGEMENT STANDARDS AND ORGANIZATIO LESSONS LEARNED FROM RECENT EVENTS-7-
NOVEMBER i, 1994 ENFORCEMENT CONFERENCE PALISADES *DIESEL GENERATORS ISSUE: CONTROL OF MAINTENANCE EXAMPLES
D/G mechanical governor replaced without adequate post-maintenance test to assure engine could still ~chieve peak load (2,800 KW).
- D/G mechanical governor output linkage was misadjusted resulting in D/G incapable of achieving peak load (2,800 KW)
ROOT CAUSES
Inadequate post-maintenance test program in 1980 *
Lack of knowledge of g~vernor and interfa~e with diesel engin CORRECTIVE ACTIONS *
Adjusted governor linkage (O/G 1), hardstop (0/G 2) and performed special test to verify peak load carrying capability. *
Will perform periodic peak load testing of D/G *
Develop permanent maintenance procedure for setting fuel controls to ensure full fuel rack trave *
Training for System Engineers and Maintenance Personnel* on Woodward governor A-
- ISSUE: DESIGN AND TEST CONTROL EXAMPLES NOVEMBER 1, 1994 ENFORCEMENT CONFERENCE PALISADES *DIESEL GENERATORS
Safeti Evaluation (IO CFR 50.59) not performed for.several (more than one)
changes to diesel generator load profile *
Surveillance Test procedures not updated for changes to diesel load profile *
Tech. Spec. not revised when diesel load profiles change *
Inadequate testing/analysis to verify that load profile change was acceptable from the standpoint of the diesel generato ROOT CAUSES
Similar to issues raised by Service Water Operational *Performance Inspection and inoperable Engineered Safeguards Room Cooler *
Lack of recognition that change in load profile constitutes a desig~
chang CORRECTIVE ACTIONS
Palisades Performance Enhancement Pla *
Reinforced expectations regarding design control and con(ig~ration management through quarterly engineer continuing trainin * *
Reinforced expectation to perform safety evaluation for analysis involving changes in design or licensing basis.
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Enhance administrative controls to assure changes to plant design as a result of analysis are properly controlled and evaluated for potential verification testing.
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NOVEMBER 1, 1994 ENFORCEMENT CONFERENCE PALISADES DIESEL GENERATORS ISSUE: * VENDOR DATA AND. RECOMMENDATIONS EXAMPLES
Exceptions taken.to vendor recommended ma.intenance without adequate justification.*
Vendor ihformatioh regarding fuel rack adjustments was unclea ROOT.CAUSES
Weak administrative controls over vendor manuals and recommendation *
Lack of knowledge of governor and interface with diesel engin CORR-ECTIVE ACTIONS
Preventive Mainten~nce Optimization Progra~, which includes a structured review of all vendor PM recommendations for systems within Maint. Rule
Strengthen administrative controls of vendor manuals and recommendation *
Training for System Engineers and Maintenance Personnel on Woodward governor NOVEMBER 1, 1994 ENFORCEMENT CONFERENCE PALISADES DIESEL GENERATORS ISSUE: MANAGEMENT STANDARDS ANP ORGANIZATION EXAMPLES
Failure to implement vendor recommended maintenanc *
System performance monitoring failed to detect diesel engine degradatio *
Acceptance of position that peak load testing was not necessary or
.require *
Inadequate response to NRC EDSFI and DET concerns regarding D/G loading and testin *
Failure to complete 10 CFR 50.59 Safety Evaluations for diesel generator load change ROOT CAUSES
lack of ownership and accountability for design lackin *
Unclear role of System Enginee *
Lack of preventive maintenance program* expectation *
Inadequate corrective actio CORRECTIVE ACTION
Palisades Performance Enhancement Pla *
Re-definition of System Engineers Roles..
Preventive maintenance optimization program~
Assessment of testing of safety systems against design basi ll-
- NOVEMBER 1, 1994.
ENFORCEMENT.CONFERENCE PALISADES DIESEL GENERATORS ISSUE: LESSONS LEARNED FROM RECENT EVENTS
Questioning attitude
Troublesh6oting approach
Utilization of nuclear oversite (NPAD)
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- GENERIC IMPLICATIONS ROOT CAUSES ARE THE SAME AS FOR SWOPI, EDSFI, THERMAL OVERLOADS, INPO; DE NOVEMBER 1 * 1994 ENFORCEMENT CONFERENCE*
PALISADES DIESEL GENERATORS
Design basis understanding, sensitivity and ownership
Vendor information control and use
Design/testing controls and.50.59 use
- .Questioning approach/healthy skepticism
Engineering leadership CORRECTIVE ACTIONS COMPLETED/ONGOING
Continued follow-through on P2EP items
Restructured/refocused/consolidated engineering team supporting the plant Leadership Profile 6 new from outside CPCo 13 new assignments 18 incumbents l vacancy 8 removed
- pwnership and Training/Coaching led by management Roles and responsibilities Design basis ownership/sensitivity Troubleshooting methodology Event Investigations
Engineering daily involvement in issues
Listening to and learning from others:
Operations Management NPA NRC Maintenance INPO NPRDS CEOG-13-
- GENERIC IMPLICATIONS coN'T NEW CORRECTIVE ACTIONS NOVEMBER 1, 199 ENFORCEMENT. CONFERENCE PALISADES DIESEL GENERATORS
Review of critical safety systems for similar operability issues - Complete Batteries*
- safety Evaluations Design input linked to testing Test Results
Structured re-review of all safety systems to co~pare design, tech specs, tests-April 1995
Determination of EDG ~aintenance for 1995 Refueling~ December 15,1994-14-
NOVEMBER 1, 1994 ENFORCEMENT CONFERENCE PALiSADES DIESEL GENERATORS SAFETY SIGNIFICANCE WORST CASE EVALUATED
- EOG-1-1 degraded to 2438 KW limit
EOG 1-2 out bf service {single failure)
OBA LOCA with Loss of Offsite Power
AFW pump {largest load) starts after all other automatic and manual load are on CONCLUSIONS
EOG 1-1 was Tech Spec inoperable; however, all loads would start and
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Peak fuel temperature is reached in 63.53 seconds and limited.by SIT irijection.at 63.7 seconds
Peak containment pressure reached within 30 seconds and is limited by PCS energy release
For the first 30 minutes generator would run at approximately 58 Hz, resulting in pump flow losses of 1-4%
Between 30-32 minutes, flow loss would be.approximately 6-9%
Previous fuel vendor analysis of a potential 20% flow reduction resulted in a l0°F rise in the design analysis peak temperature of 2095°F
After 32 minutes, generator would recover to 60 Hz
All safety related electrical components would function
Reasonable margin would still exist to maintain:
2200°F fuel temperature containment peak pressure containment EEQ environment
- Conservatism exists in load profile pertaining to realistic timing of manual loadin Review of these manual loads resulted in a 104 KW decrease in the peak loa Independent review by Sargent & Lundy concurs with CPCo findings-15-
NOVEMBER
, I 1994 ENFORCEMENT CONFERENCE PALISADES DIESEL GENERATORS MITIGATING FACTORS
- SELF IDENTIFIED
COMPREHENSIVE EVALUATION AND CORRECTIVE ACTIONS
PREVIOUS IDENTIFICATION OF PROGRAMMATIC ISSUES AND ONGOING-.
PERFORMANCE ENHANCEMENT PROGRAM
REDUCED BUT ADEQUATE SAFETY MARGIN {NO IMPACT ON HEALTH AND SAFETY OF PUBLIC)
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NPAD PERFORMANCE NOVEMBER 1, 1994 ENFORCE~ENT CONFERENCE PALISADES DIESEL GENERATORS
Issues raised by NPAD in e~rly 1994 contributed to self-identification of, the issu *
- Pre-July '94, NPAD performance deficiencies were already capt~red in a performance improvement plan'.
Primary NPAD lesson learned:* More attention needed by NPAD in comparing line response with safety significance/management expectation and subsequent feedback to management.
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NOVEMBER 1, 1994 ENFORCEMENT CONFERENCE PALISADES DIESEL GENERATORS MANAGEMENT LESSONS LEARNED QUESTIONING ATTITUDE; ACCEPTANCE OF THE DESIRED ANSWER; LACK OF SYSTEMATIC TROUBLESHOOTING; - INADEQUATE COMMUNICATIONS; INVOLVEMENT OF THE PRC; ORGANIZATION OF THE ENGINEERING FUNCTION; 7. -RECOGNIZING OUR LIMITATIONS;. EFFECTIVENESS OF PAST CORRECTIVE ACTIONS; 9.. NPADs ROLE I POSITIVE LESSONS NOTED:
a. Operators questioning EDG performance b. Plant management continued to pursue item c. Engineering heavily involved
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d. PPEP actions targeted at the same causes e. CPCO caught this item and pursued it to resolution 1 OPPORTUNITY: TO REINFORCE THE LESSONS LEARNED FROM THIS EXAMPLE TO THE REST OF OUR MANAGEMENT, OPERATIONS, ENGINEERING, AND MAINTENANCE STAFF; 1 PALISADES PERFORMANCE ENHANCEMENT PLAN:
1.2 tlear Roles and Responsibilities 1.3 Management Expectations and. Standards Improved Corrective Action Process 2.4 Enhanced Modification Process 2.6 Enhanced Operability Determination Process Enhanced Employee Knowledge-and Skills 4. I Define and Convnuni cate NOD Nuclear Safety Philosophy 4.2 Establish Strong Sensitivity to Plant Design Basis Establish Critical Self-Assessment as a Norm-18-
FIGURE I FIGURE 2 FIGURE 3 FIGUR FIGURE 5 FIGURES Emergency Diesel Generator~l-1 Peak Loading Woodward Governor Schematic System Engineer's Job Standard questions to ask during Event Evaluation - Draft Proposed Corrective Actions
Emergency Diesel Generator 1-1 Peak Loadings KW 3000
--- Engine 2 hr. Roting !2,864>
F octory Lood Test 2810 <32.5mml 2750 --'---DIG 2 hr. Roting <2,750>
--- Polisodes Preop Test 2720 !31.5mml
--- Engine Roting !2,6lll
. 2,645 ' 2,688 2,645r- - - - - -
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'93" I
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- 2,584
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"94'
2. 5r..4
"87' 2,498
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2500 -+--DIG Roting <2~500>
2250 2000 I
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1U 2,451_ - ~.L -'"88'..
2,430 ;
'86' 2458 r-.34*
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- - - - - - - - - - - - - - - -.,.. - - - - - - -'
1,970
'83'
1750--+---------;._.,....---------._.----.---.-----,..---,..---,..---.---.--.--.--.--.--.--.--r---r---r---..--.
2000 Year
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FIGURE 2 Woodward Governor Schematic
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.. MAIN BUS I
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CIRC~IT
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(
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. TO AMMETERS RESISTOR BOX LOAD SENSOR r- - - - -.,Aux. CONTACTS PARALLELING LINES. COMMON TO OTHER EG UNIT,S
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BAE ""
.. r ON SW'>CH80ARO
'--+-+-+-+--......... ~--"-+-<'!
I DROOP 10N MAIN CIRCUIT
. I SWITCH 1BREAKER CLOSE CURRENT TRANSFORMERS SEE NOTE i
LOAD GAIN IADJUSTABLEI I DROOP t 1WHEN BREAKER CLOSES I
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11SOCH t
....-J.......
.......... -----0 o--~-~~
,SEE
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r NOTE 4
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I DE DROOP I
DROOP CONTROL IAOJUSTABLEI SPM INPUT I
LOAD PULSE
.._ _____..... _...;. _____ J TO VOL TMETE ON SWI !CHBOARD SPEED SENSOR SEE NOTE 1
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r---.-~,
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r-*--*'"'1 I
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l-0 A
I HYDRAULIC GENERATOR PRIME MOVER I
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- _ ______ J NOTES:
1. JUMPER BETWEEN TERMINALS 23 AND 24 FOR 60 HZ OPERATION. REMOVE JUMPER FOR SO HZ OPERATIO. FOR A BALANCED UNITY POWER FACTOR LOAD, THE FOLLOWING VOLTAGES MUST BE IN PHASE AT THE CONTROL BOX INPUT:
4 TO 1 WITH 6 Tb 5 4 TO 2 WITH B TO 7 4TOJWITH 10T09
.ACTUATOR I
I-<> B I
AMPLIFIER 17 IGAIN ADJUSTABLE I L-----J STABILITY CONTROL IAOJUSTABLEI 3. SWITCHES, RELAYS. WIRING, ETC., NOT FURNISHED BY WOODWARD GOVERNOR COMPAN. DE*DROOP AND LOAD PULSE CIRCUITS ARE OPTIONAL. SEE OPERATION AND PRINCIPLES OF OPERATION SECTIONS FOR DETAIL.*,
FIGURE 3 SYSTEM ENGINEER'S JOB You are the system owner/manager. Know your system and the plant. Assure your
- system meets design and licensing requirements. Continually assess and improve the health of your system. Provide leadership for issues affecting the health of your syste. _
Know your system and the plant, including how the system is designed and operated in various mode *
. System & integrated plant design Accident analysis assumptions Emergency operating procedures System design and liqensing basis *
Maintenance rule
.Accident function Normal operating function System operating procedures Probabilistic risk assessment Generic letter 91 ~ l 8 'Assure yo*ur system meets design and licensing requireme11ts_, This requires an understanding of how the current design m~ets the design arid licen~ing -basi Technical specifications Design and licensing. basis NRC.generic letters/bulletins/notices Regulatory commitments FSAR Maintenance rule function and performance criteria Continually assess and improve the health of your system. You must know the current material condition of your system, its current performance level, and th operator's frustrations with the syste Trends - performance indicators,* CFAR Past system failures and events Corrective maintenance backlog Special/augmented tests Industry issues
Operations staff input Temporary modification's System modifications plans Predictive maintenance System walkdowns Maintenance history Technical specification surveillances Corrective actions
System notebook Caution tags Assessment of vulnerabilities Preventive maintenance optimization and maintenance basis Provide leadership for issues affecting the health of your syste Adverse system performance trends - proactive monitoring and resolution of issues System failures and transients - control room presence/response to Operations System modifications/design issues - know when to get design engineering involved Corrective maintenance - coordinate, stay informed; but you are not maintenance engineers
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FIGURE 4 Standard Questions To Ask Du~ing Event Evaluations (DRAFT)
QUESTION I
ANSWER How did we find this?
What opportunities did we miss to find this?
Has this happened before?
Where else could this or a similar issue exist?
Has operability been thorough 1 y evaluated?
What does the vendor think?
How do we compare to other plants?
Why did this happen?
Are there PRA implications?
What does INPO think?
I'm conc~rned if we kn.ow enough about this?
Are there any more issues like this?
What's NPRDS tell us?
Should we have PRC review this?
Have a 11. the right people been involved?
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FIGURE 5 PROPOSED CORRECTIVE ACTIONS:
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Revise MO-7 A-1 and MO-7 A-2 to take rack readings every month
- and establish correlation of rack reading to load available to satisf OBA requirements. Install temporary transducer to_ obtain accurate.
KW readings during the monthly reading.
Bring trend data graphs up to date from 1992 and verify that correct
- indicators are being trende.
. Evaluate and document safety significance of degraded EOG 1-1 and 1-2 performanc.
Revise ONP-20 - add resistor to EGA controls when cable is
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removed to provide additional protection to the EGA during this*
activity. * *Provide specific training to the Maintenance Planners on the lessons learned from these corrective actions (when adjustments are made that affect equipment's ability to meet design, then one needs to verify the equipment's ability to meet those design requirements). * Documenta transition plan for systems engineering as part of reorganization. The plan should include the following elements: Prioritizing work load to facilitate System Engineers time to familiarize themselves with system and associated equipmen Formalize turn over from one System Engineer to the new System Enginee Develop strategy for deciding System Engineer assignments in sufficient time to accomplish adequate turnover and training prior to assuming system responsibilitie Capture institutional knowledge in real time using techniques such as System Notebooks, et *
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- 1 FIGURE 5 * Provide specific training to Technical Staff on the lessons learned from these corrective actions. Foster the understanding that design changes (ie. Analysis) and modifications, which change or add design basis shall be properly controlled and validated by testin Address the affect of these changes on SOP's, EOP's, ONP's, Tec Spec. Tests, design basis and other design documents.* *. Complete assessment of performance of key safety systems against the plant design basis. Review performance tests to assure design
. basis assumptions and requirements are satisfied/verifie Complete top 5 PRA Systems. Verify that all actions for D-PAL-93-.
272U are satisfie.
Complete short-duration monthly peak load tests for both EDGs during the next two monthly tests. The monthly testing will monitor engine performance and establish trend information, pertaining to-fuel rack position relative to KW loading, at loads of 2300 KW and abov.
. Revise EPS-E-1 prior to next procedure use, to address the mechanical governor setpoints and reasons for setpoint Withdraw procedure from use until revised..
1 Revise RM-63, refueling outage PM activity for EDGs, to ensure that lessons learned are incorporated. Specifically, for mechanical changes to performance, need to check *for stability and verify proper rack travel. Incorporate necessary changes from action item 1.
Determine the root cause for the apparent minor engine degradation that has occurred on EOG 1-1 and EDG 1-2 with respect to the original 1969.engine testing..
13. * Establish administrative controls to ensure that changes to the plant design basis that occur through analysis are properly controlled and evaluated for potential verification testing. Foster the understanding that analysis which change design basis are modifications and post-modification testing should be considered to validate the plant desig.. -
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FIGURE 5 Enhance the EA Checklist to address affect on EOP's, ONP's, other design documents and post-modification testing to verify ability to meet design requirement.
Evaluate the vendor recommended maintenance practices against current maintenance practices. Document/justify any deviations from recommended practice.
Write a maintenance procedure that tells exactly how to set the fuel control on the EOG to obtain full rack travel. Revise information in ALCO manual on fuel rack adjustments if necessar.
Provide EOG, Aux Feedwater and Main Feedwater System Engineers appropriate Woodward Governor Trainin * - 1 Need to evaluate replacement of EOG 1-1 and EOG 1-2 wattmeters_
for calibration frequency and accurac.
Evaluate the design margin that exists for both EOGs with respect to the maximum accident required loads and determine the possible alternatives that exist to increase the margi.
_ Establish preventative maintenance controls to periodically monitor
. engine governor performance and control setpoints to ensure governors perform as expected in both "Parallel" and "Unit" modes.*
Check EGA waveform stability and EOG load stabilit.
Upon the completion of Action 9, (monthly peak load testing},
establish operability criteria in the monthly EOG test procedures to ensure that EOG load carrying capability for design basis loads is verified. At this time it is anticipated that available fuel rack travel at a given load, with a known correlation between available travel and * *
load output, will provide; an accurate method to monitor design basis capabilitie.
Establish periodic design basis testing for both EDGs. The anticipated testing interval is once each refueling cycle, and will be based on the results from the trending ancj testing from Actions 9 and 2 i. ~.:"".
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FIGURE 5 Complete assessment of performance of key safety systems against the plant design basis. Review performance tests to assure design basis assumptions and requirements are satisfied/verifie Complete next 10 Key Systems. *
Complete assessment of performance of key safety systems against the plant design basis. Review_ performance tests to assure design basis assumptions and requirements are satisfied/verifie *
Complete remaining system Based on results of action Item 12, evaluate the need to enhance the present performance monitoring program for the-EDGs to maintain the engin~s at or near peak performanc,
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Submit change to Tech Spec section 4. 7 to include testing/verification of EOG ability to supply design basis loads and update basis sectio