IR 05000255/2004003
| ML041390279 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/18/2004 |
| From: | Julio Lara NRC/RGN-III/DRS/EEB |
| To: | Domonique Malone Nuclear Management Co |
| References | |
| IR-04-003 | |
| Download: ML041390279 (32) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT NRC SAFETY SYSTEM DESIGN AND PERFORMANCE CAPABILITY INSPECTION REPORT 05000255/2004003(DRS)
Dear Mr. Malone:
On April 9, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palisades Nuclear Plant. The enclosed safety system design and performance capability inspection report documents the inspection findings, which were discussed on April 9, 2004, with Mr. P. Harden and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and to compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on the design and performance capability of the auxiliary feedwater and emergency diesel generator systems to ensure that they were capable of performing their required safety related functions.
Based on the results of this inspection, one NRC-identified finding of very low safety significance (Green) was identified in the report. This finding was determined to involve a violation of NRC requirements. However, because the violation was of very low safety significance and because the issue was entered into your corrective program, the NRC is treating this finding as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Palisades Nuclear facility. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Julio F. Lara, Chief Electrical Engineering Branch Division of Reactor Safety Docket No. 50-255 License No. DPR-20 Enclosure: Inspection Report 05000255/2004003(DRS)
w/Attachment: Supplemental Information cc w/encl: J. Cowan, Executive Vice President and Chief Nuclear Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor Michigan Department of Environmental Quality -
Waste and Hazardous Materials Division Michigan Department of Attorney General
SUMMARY OF FINDINGS
IR 05000255/2004003(DRS); 03/22/2004 - 04/09/2004; Palisades Nuclear Plant; Safety System
Design and Performance Capability Inspection.
This report covers an announced biennial safety system design and performance capability inspection. The inspection was conducted by Region III inspectors. The inspection focused on the design and performance capability of the auxiliary feedwater (AFW) and emergency diesel generator (EDG) systems to ensure that the systems were capable of performing their required safety related functions. One Green Non-Cited Violation (NCV) of very low safety significance was identified. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
A. Inspector-Identified and Self-Revealed Findings
Cornerstone: Mitigating Systems
- Green.
A finding of very low safety significance was identified for the failure to maintain the design basis configuration (i.e., physical separation) between Auxilliary Feedwater (AFW) system trains. Specifically, the licensees facility change that converted the spare high pressure safety injection pump into the independent AFW train C was to be physically separated from the AFW trains A and B. However, the AFW trains A and B common pump discharge header piping was routed through the west safeguards (WESG) room, where the AFW train C pump was located. The primary cause of this finding was that the licensees facility change provided no engineering evaluation that demonstrated the as-built configuration was acceptable.
This issue was more than minor because the lack of physical separation between the AFW trains A and B common pump discharge header piping and the AFW train C pump affected the mitigating systems cornerstone objective. Specifically, a common pump discharge header piping break in the WESG room could potentially cause a failure of the AFW train C pump. As a result, the cornerstone objective of ensuring the availability, reliability, and capability of the AFW system to respond to initiating events was affected. The issue was of very low safety significance because it did not represent an actual loss of a safety function as determined by the licensees subsequently documented engineering analysis. The issue was a Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to maintain the design basis configuration (i.e., physical separation) between AFW system trains.
(Section 1R21.2b)
Licensee-Identified Violations
None.
REPORT DETAILS
Summary of Plant Status
The plant operated at or near full power throughout the inspection period.
REACTOR SAFETY
Cornerstones: Mitigating Systems, Barrier Integrity
1R21 Safety System Design and Performance Capability
Introduction:
Inspection of safety system design and performance capability verifies the initial design and subsequent modifications and provides monitoring of the capability of the selected systems to perform design basis functions. As plants age, the design bases may be lost and important design features may be altered or disabled. The plants risk assessment model was based on the capability of the as-built safety system to perform the intended safety functions successfully. This inspectable area verifies aspects of the mitigating systems cornerstone for which there are no indicators to measure performance.
The objective of the safety system design and performance capability inspection was to assess the adequacy of calculations, analyses, other engineering documents, and operational and testing practices that were used to support the performance of the selected systems during normal, abnormal, and accident conditions.
The systems and components selected were the auxiliary feedwater (AFW) system and the emergency diesel generator (EDG) system. These systems were selected for review based upon:
- having a high probabilistic risk analysis ranking;
- having had recent significant issues; and
- not having received recent NRC review.
The criteria used to determine the acceptability of the systems performance was found in documents such as:
- applicable technical specifications;
- applicable updated safety analysis report (USAR) sections; and
- the systems' design documents.
The following system and component attributes were reviewed in detail:
System Requirements Process Medium - water, air, electrical signal; Energy Source - electrical power, steam, air; Control Systems - initiation, control, and shutdown actions; Operator Actions - initiation, monitoring, control, and shutdown; and Heat Removal - cooling water and ventilation.
System Condition and Capability Installed Configuration - elevation and flow path operation; Operation - system alignments and operator actions; Design - calculations and procedures; and Testing - level, flow rate, pressure, temperature, voltage, and current.
Component Level Equipment/Environmental Qualification - temperature and radiation; and Equipment Protection - fire, flood, missile, high energy line breaks (HELBs), freezing, heating, ventilation and air conditioning.
.1 System Requirements
a. Inspection Scope
The inspectors reviewed the USAR, technical specifications, system descriptions, drawings and available design basis information to determine the performance requirements of the AFW and the EDG systems. The reviewed system attributes included process medium, energy sources, control systems, operator actions, and heat removal. The rationale for reviewing each of the attributes was:
Process Medium: This attribute required review to ensure that the selected systems flow paths would be available and unimpeded during and following design basis events.
To achieve this function, the inspectors verified that the systems would be aligned and maintained in an operable condition as described in the plants USAR, technical specifications and design bases.
Energy Sources: This attribute required review to ensure that the selected systems motive and/or electrical source would be available and/or adequate and unimpeded during and following design basis events, that appropriate valves and system control functions would have sufficient power to change state when required. To achieve this function, the inspectors verified that the interactions between the systems and their support systems were appropriate such that all components would operate properly when required.
Controls: This attribute required review to ensure that the automatic controls for operating the systems and associated systems were properly established and maintained. Additionally, review of alarms and indicators was necessary to ensure that operator actions would be accomplished in accordance with design requirements.
Operations: This attribute was reviewed because the operators perform a number of actions during normal, abnormal and emergency operating conditions that have the potential to affect the selected systems operation. In addition, the emergency operating procedures (EOPs) require the operators to manually realign the systems flow paths during and following design basis events. Therefore, operator actions play an important role in the ability of the selected systems to achieve their safety related functions.
Heat Removal: This attribute was reviewed to ensure that there was adequate and sufficient heat removal capability for the selected systems.
b. Findings
No findings of significance were identified.
.2 System Condition and Capability
a. Inspection Scope
The inspectors reviewed design basis documents and plant drawings, abnormal and emergency operating procedures, requirements, and commitments identified in the USAR and technical specifications. The inspectors compared the information in these documents to applicable electrical, instrumentation and control, and mechanical calculations, setpoint changes and plant modifications. The inspectors also reviewed operational procedures to verify that instructions to operators were consistent with design assumptions.
The inspectors reviewed information to verify that the actual system condition and tested capability was consistent with the identified design bases. Specifically, the inspectors reviewed the installed configuration, the system operation, the detailed design, and the system testing, as described below.
Installed Configuration: The inspectors confirmed that the installed configuration of the AFW and EDG systems met the design basis by performing detailed system walkdowns. The walkdowns focused on the installation and configuration of piping, components, and instruments; the placement of protective barriers and systems; the susceptibility to flooding, fire, or other environmental concerns; physical separation; provisions for seismic and other pressure transient concerns; and the conformance of the currently installed configuration of the systems with the design and licensing bases.
Operation: The inspectors performed procedure walk-throughs of selected manual operator actions to confirm that the operators had the knowledge and tools necessary to accomplish actions credited in the design basis.
Design: The inspectors reviewed the mechanical, electrical and instrumentation design of the AFW and EDG systems to verify that the systems and subsystems would function as required under accident conditions. The review included a review of the design basis, design changes, design assumptions, calculations, boundary conditions, and models as well as a review of selected modification packages. Instrumentation was reviewed to verify appropriateness of applications and set-points based on the required equipment function. Additionally, the inspectors performed limited analyses in several areas to verify the appropriateness of the design values.
Testing: The inspectors reviewed records of selected periodic testing and calibration procedures and results to verify that the design requirements of calculations, drawings, and procedures were incorporated in the system and were adequately demonstrated by test results. Test results were also reviewed to ensure automatic initiations occurred within required times and that testing was consistent with design basis information.
b. Findings
Introduction:
The inspection team identified a Non-Cited Violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control, having very low safety significance (Green) for the failure to maintain the design basis configuration (i.e., physical separation) between AFW system trains. Specifically, the licensees facility change that converted the spare high pressure safety injection (HPSI) pump into the independent AFW train C was to be physically separated from the AFW trains A and B. However, the AFW trains A and B common pump discharge header piping was routed through the west safeguards (WESG) room, where the AFW train C pump was located. The licensees facility change provided no engineering evaluation that demonstrated the as-built configuration was acceptable.
Description:
The inspectors reviewed the licensees documentation for facility change FC-516-2, Modification to the Auxiliary Feedwater System in Response to NUREG-0737, dated February 19, 1982. This facility change converted the spare HPSI pump into a third AFW pump (train C). The facility change design bases included guidelines set forth in NUREG-0737, "Clarification of TMI Action Plan Requirements,"
dated November 1980, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 10, Steam and Power Conversion System, Section 10.4.9, Auxiliary Feedwater System (PWR), dated July 1981, and BTP Auxiliary Systems Branch (ASB) 10-1, Design Guidelines for Auxiliary Feedwater System Pump Drive and Power Supply Diversity for Pressurized Water Reactor Plants, dated July 1981. The facility change was performed, in part, to minimize the effects of common mode failures and single failures on the existing AFW system. The licensees safety evaluation associated with the facility change indicated that by adding a third auxiliary feedwater pump which is located in a separate room, these single failure modes identified in the study are eliminated, and the system reliability is increased.
The conceptual design associated with the facility change also indicated separation of discharge lines from each AFW pump. In a letter to the NRC on November 2, 1981, the licensee stipulated that this modified design incorporates a third AFW pump in a location which is physically separate from the existing pumps which are to be retained as-is.
To determine if the lack of AFW train separation in the WESG room had been previously identified as part of the original facility change process, the inspectors reviewed associated correspondence from the licensee to NRR, correspondence from NRR to the licensee, and requested any other documentation that evaluated the lack of physical separation in the WESG room. The licensee could not identify or provide any engineering evaluation that demonstrated that the lack of physical separation was acceptable. As a result, on April 8, 2004, the licensee initiated CAP041023, AFW HELB Licensing Issue.
Subsequent to this inspection, the licensee completed a follow-up engineering analysis EA-CAP041023-01, Documentation of the Design and Licensing Bases for the Auxiliary Feedwater System as it Relates to Train Separation and Potential Piping Failure, dated April 22, 2004. This engineering analysis stated that NUREG-0800, BTP MEB 3-1, Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment, classified moderate energy systems as those systems which were high energy less than 2 percent of the time the system was in operation or were high energy less than 1 percent of the total plant operating time. Although the licensee had not administratively prohibited using AFW trains A and B for startup and shutdown activities, AFW train C had been dedicated historically by the licensee for these activities. The licensees review of past usage of AFW trains A and B as documented in the engineering analysis confirmed that this subsystem would have met the definition of moderate energy based on time used. As a moderate energy subsystem with pipe stress less than the MEB 3-1 acceptance limits, line breaks and cracks of the AFW trains A and B common pump discharge header piping located in WESG room would not need to be postulated for this section of piping. Therefore, based on low past usage of the AFW trains A and B, the licensee concluded that the AFW system would have been operable with the lack of physical separation in the WESG room.
Analysis:
The inspection team determined that failing to provide a necessary engineering analysis was a licensee performance deficiency warranting a significance evaluation. The licensee failed to maintain the specified design basis configuration for AFW train separation in the WESG room as demonstrated by not evaluating the lack of physical separation in facility change FC-516-2 for acceptability. The inspection team concluded that the finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Disposition Screening, issued on April 29, 2002, because the potential to affect the AFW systems design basis function (i.e., degradation of decay heat removal during emergency and shutdown operations)affected the mitigating systems cornerstone objective. Facility change FC-516-2 specified that the new independent AFW pump (train C) was to be physically separated from the AFW trains A and B to increase AFW system reliability from single failures of the existing AFW system. The AFW trains A and B common header discharge piping was routed through the WESG room where the AFW train C pump was located. The impact of this lack of physical separation between the AFW trains was not evaluated to demonstrate acceptance. As a result, the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of the AFW system to respond to initiating events was affected.
The inspection team processed the finding through Phase I of the NRCs significance determination process. The inspectors concurred with the licensees operability position that with the lack of AFW subsystem separation in the WESG room that the AFW system would have performed its safety function. The historical usage of the AFW trains A and B met the criteria for a moderate energy system, and the maximum piping stress was less than MEB 3-1 acceptance limits. The inspectors determined that line breaks and through wall cracks for the AFW trains A and B common discharge header piping inside the WESG room need not be postulated for the system operability determination. The inspectors concluded that the finding was a performance deficiency that did not represent an actual loss of a safety function of a safety-related system.
Therefore, this finding screened out and was considered to be of very low safety significance (Green).
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, from 1982 until April 22, 2004, the design basis of the AFW system was not correctly maintained, in that, the physical separation of the AFW trains A and B common discharge header piping from the AFW train C pump was not maintained and the acceptability of this configuration was not demonstrated in facility change FC-516-2. As a result, the potential existed for AFW system operability concerns due to a failure of the AFW trains A and B common discharge header piping in the WESG room. The licensee subsequently implemented appropriate corrective actions to address this violation. The licensee performed an analysis of the AFW system to demonstrate that the existing configuration was acceptable, notwithstanding the physical separation between redundant AFW trains.
Because this violation was of very low safety significance and it was entered into the licensees corrective action program (CAP041023), this violation is being treated as a NCV, consistent with Section VI.A of the NRC Enforcement Policy.
(NCV 05000255/2004003-01(DRS))
.3 Components
a. Inspection Scope
The inspectors examined the AFW and EDG systems associated pumps, heat exchangers and instrumentation to ensure that component level attributes were satisfied.
Equipment/Environmental Qualification: This attribute verifies that the equipment was qualified to operate under the environment in which it was expected to be subjected to under normal and accident conditions. The inspectors reviewed design information, specifications, and documentation to ensure that the AFW and EDG systems were qualified to operate within the temperatures and radiation fields specified in the environmental qualification documentation.
Equipment Protection: This attribute verifies that the AFW and EDG systems were adequately protected from natural phenomenon and other hazards, such as HELBs, floods or missiles. The inspectors reviewed design information, specifications, and documentation to ensure that the systems were adequately protected from those hazards identified in the USAR, which could impact the systems ability to perform their safety function.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Review of Condition Reports
a. Inspection Scope
The inspectors reviewed a sample of problems associated with the AFW and EDG systems that were identified and entered into the corrective action program by the licensee. The inspectors reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, condition reports written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the corrective action system. The specific corrective action documents that were sampled and reviewed by the team are listed in the attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings
.1 Exit Meeting
The inspectors presented the inspection results to Mr. P. Harden and other members of licensee management at the conclusion of the inspection on April 9, 2004. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
.2 Interim Exit Meetings
No interim exits were conducted.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- G. Baustian, Training Manager
- J. Broschak, Design Engineering Manager
- R. Brzezinski, I&C/Electrical Design Supervisor
- M. Carlson, Engineering Director
- E. Chatfield, Performance Improvement Supervisor
- M. Coddington, Design Engineering (Shadow)
- B. Dotson, Regulatory Compliance
- D. Fitzgibbon, Balance of Plant Supervisor (Shadow)
- E. Halverson,Design Engineering
- B. Hamm, Electrical Design
- P. Harden, Director Plant Operations
- G. Hettel, Plant General Manager
- G. Higgs, Maintenance Manager
- D. Kennedy, Design Engineering (Shadow)
- J. Kingseed, Engineering Programs Manager
- L. Lahti, Regulatory Affairs Manager
- D. Malone, Regulatory Compliance Supervisor
- R. Margol, Chemistry Supervisor
- S. Oakley, Operations (Shadow)
- B. Rash, System Engineering Manager
- R. Remus, Assistant Plant General Manager
- J. Schepers, Nuclear Oversight
- T. Steffler, Operations (Shadow)
- A. Stover, Nuclear Oversight Manager
- D. VandeWalle, Assistant Operations Manager
- B. VanWagner, Reliability Supervisor
- S. Wawro, Asset Manager (Consumers Energy)
- R. Werdann, Scheduling Manager
- D. Wilson, Vice President Nuclear Assessment
Nuclear Regulatory Commission
- J. Lennartz, Senior Resident Inspector
- M. Garza, Resident Inspector
A1 Attachment
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000255/2004003-01(DRS) NCV Failure to Maintain AFW Design Basis Physical Separation (Section 1R21.2b)
Closed
- 05000255/2004003-01(DRS) NCV Failure to Maintain AFW Design Basis Physical Separation (Section 1R21.2b)
Discussed
None.