ML090150569

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IR 05000255-08-009; on 11/03/2008 - 12/04/2008; Palisades Nuclear Plant; Component Design Bases Inspection (CDBI)
ML090150569
Person / Time
Site: Palisades Entergy icon.png
Issue date: 01/15/2009
From: Ann Marie Stone
NRC/RGN-III/DRS/EB2
To: Schwarz C
Entergy Nuclear Operations
References
IR-08-009
Download: ML090150569 (36)


See also: IR 05000255/2008009

Text

January 15, 2009

Mr. Christopher J. Schwarz

Vice President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANT

NRC COMPONENT DESIGN BASES INSPECTION (CDBI)

INSPECTION REPORT 05000255/2008009(DRS)

Dear Mr. Schwarz:

On December 4, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed a component

design bases inspection at your Palisades Nuclear Plant. The enclosed report documents the

inspection results, which were discussed on December 4, 2008, with you and other members of

your staff.

The inspection examined activities conducted under your license as they relate to safety and

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.

Based on the results of this inspection, two NRC-identified findings of very low safety significance

were identified. The findings involved violations of NRC requirements. However, because of

their very low safety significance, and because the issues were entered into your corrective action

program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with

Section VI.A.1 of the NRC Enforcement Policy.

If you contest the subject or severity of these NCVs, 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 Plant.

C. Schwarz -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any), will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agency wide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure: Inspection Report 05000255/2008009

(w/Attachment: Supplemental Information)

cc w/encl: Senior Vice President

Vice President Oversight

Senior Manager, Nuclear Safety & Licensing

Senior Vice President and COO

Assistant General Counsel

Manager, Licensing

W. DiProfio

W. Russell

G. Randolph

Supervisor, Covert Township

Office of the Governor

T. Strong, State Liaison Officer

Michigan Department of Environmental Quality

Michigan Office of the Attorney General

C. Schwarz -2-

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,

its enclosure, and your response (if any), will be available electronically for public inspection in

the NRC Public Document Room or from the Publicly Available Records System (PARS)

component of NRC's Agency wide Documents Access and Management System (ADAMS),

accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public

Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-255

License No. DPR-20

Enclosure: Inspection Report 05000255/2008009

(w/Attachment: Supplemental Information)

cc w/encl: Senior Vice President

Vice President Oversight

Senior Manager, Nuclear Safety & Licensing

Senior Vice President and COO

Assistant General Counsel

Manager, Licensing

W. DiProfio

W. Russell

G. Randolph

Supervisor, Covert Township

Office of the Governor

T. Strong, State Liaison Officer

Michigan Department of Environmental Quality

Michigan Office of the Attorney General

DOCUMENT NAME: G:\DRS\Work in Progress\PAL 2008-009 CDBI JEN.doc

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE RIII RIII

NAME JNeurauter: ls AMStone

DATE 01/08/09 01/15/09

OFFICIAL RECORD COPY

Letter to Mr. Christopher J. Schwarz from Mrs. A. M. Stone dated January 15, 2009.

SUBJECT: PALISADES NUCLEAR PLANT

NRC COMPONENT DESIGN BASES INSPECTION (CDBI) REPORT

05000255/2008009(DRS)

DISTRIBUTION:

Tamara Bloomer

RidsNrrPMPalisades

RidsNrrDorlLpl3-1

RidsNrrDirsIrib Resource

Mark Satorius

Kenneth Obrien

Jared Heck

Carole Ariano

Linda Linn

Cynthia Pederson

DRPIII

DRSIII

Patricia Buckley

Tammy Tomczak

ROPreports@nrc.go

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-255

License No: DPR-20

Report No: 05000255/2008009(DRS)

Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant

Location: Covert, MI

Dates: November 3, 2008, through December 4, 2008

Inspectors: J. Neurauter, Senior Engineering Inspector, Lead

A. Dahbur, Senior Engineering Inspector

M. Bielby, Senior Operations Examiner

N. Feliz-Adorno, Engineering Inspector

C. Baron, Mechanical Contractor

S. Kobylarz, Electrical Contractor

C. Scott, Engineering Inspector (Training)

Approved by: Ann Marie Stone, Chief

Engineering Branch 2

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000255/2008009(DRS); 11/03/2008 - 12/04/2008; Palisades Nuclear Plant; Component

Design Bases Inspection (CDBI).

The inspection was a 3-week onsite baseline inspection that focused on the design of

components that are risk-significant and have low design margin. The inspection was

conducted by regional engineering inspectors and two consultants. Two findings of very low

safety significance were identified which were associated Non-Cited Violations (NCVs). 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 NRCs program for overseeing the safe operation of commercial

nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4,

dated December 2006.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

  • Green. A finding of very low safety significance (Green) and associated NCV of 10 CFR

Part 50, Appendix B, Criterion III, Design Control, was identified by the inspectors for the

failure to assure the loading on emergency diesel generator 1-2 was maintained within the

2-hour rating. Specifically, the licensee failed to evaluate the worst case design loading

and procedurally allowed manual loading conditions when determining the emergency

diesel generator load required for design basis loss-of-coolant-accident and loss-of-offsite-

power conditions. The licensee entered the issue into their corrective action program and

performed an operability review to verify that the diesel generator would be capable of

supplying the calculated load.

The finding was more than minor because it was similar to IMC 0612, Appendix E,

Example 3.j, in that there was a reasonable doubt on the operability of emergency diesel

generator 1-2, since emergency diesel generator loading conditions above the 2-hour

rating were neither adequately calculated nor periodically tested. The inspectors

determined the finding was of very low safety significance because it was a design

deficiency that did not result in actual loss of safety function. The inspectors did not

identify a cross-cutting aspect associated with this finding because the performance

deficiency was related to a historical design issue and not indicative of current licensee

performance. (Section 1R21.3.b.(1))

  • Green. A finding of very low safety significance (Green) and associated NCV of 10 CFR

Part 50, Appendix B, Criterion III, Design Control, was identified by the inspectors for the

failure to correctly translate the applicable design basis into the Technical Specifications

limit for the emergency diesel generator, day tank fuel oil volume. Specifically, the

licensee failed to incorporate the appropriate emergency diesel generator load profile

when calculating the emergency diesel generator fuel oil consumption. The Technical

Specifications requirement for the day tank fuel oil volume assured an allowed outage time

for the limiting fuel oil transfer pump. This finding resulted in a non-conservative Technical

Specifications value. As a result, the licensee implemented compensatory actions to

administratively limit the allowed outage time for the limiting fuel oil transfer pump that

corresponded to the available day tank fuel.

1 Enclosure

The inspectors determined that the finding was more than minor because the finding was

associated with the Mitigating Systems cornerstone attribute of equipment performance

and affected the cornerstone objective of ensuring availability of the emergency diesel

generator to respond to initiating events to prevent undesirable consequences. The

finding screened as of very low safety significance because the finding was a design or

qualification deficiency confirmed not to result in loss of operability or functionality. The

inspectors did not identify a cross-cutting aspect associated with this finding because the

performance deficiency was related to a historical design issue and not indicative of

current licensee performance. (Section 1R21.3.b.(2))

B. Licensee-Identified Violations

No violations of significance were identified.

2 Enclosure

REPORT DETAILS

1. REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Component Design Bases Inspection (CDBI) (71111.21)

.1 Introduction

The objective of the CDBI is to verify that design bases have been correctly

implemented for the selected risk-significant components and that operating procedures

and operator actions are consistent with design and licensing bases. As plants age,

their design bases may be difficult to determine and an important design feature may be

altered or disabled during a modification. The Probabilistic Risk Assessment (PRA)

model assumes the capability of safety systems and components to perform their

intended safety function successfully. This inspectable area verifies aspects of the

Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, for which there

are no indicators to measure performance.

Specific documents reviewed during the inspection are listed in the Attachment to this

report.

.2 Inspection Sample Selection Process

The inspectors selected risk-significant components and operator actions for review

using information contained in the licensees PRA and the Palisades Standardized Plant

Analysis Risk (SPAR) Model, Revision 3P. In general, the selection was based upon the

components and operator actions having a risk achievement worth of greater than 1.3

and/or a risk reduction worth greater than 1.005. The operator actions selected for

review included actions taken by operators both inside and outside of the control room

during postulated accident scenarios. In addition, the inspectors selected operating

experience issues associated with the selected components.

The inspectors performed a margin assessment and detailed review of the selected

risk-significant components to verify that the design bases have been correctly

implemented and maintained. This design margin assessment considered original

design reductions caused by design modification, or power uprates, or reductions due to

degraded material condition. Equipment reliability issues were also considered in the

selection of components for detailed review. These included items such as performance

test results, significant corrective action, repeated maintenance activities, Maintenance

Rule (a)(1) status, components requiring an operability evaluation, NRC resident

inspector input of problem areas/equipment, and system health reports. Consideration

was also given to the uniqueness and complexity of the design, operating experience,

and the available defense in depth margins. A summary of the reviews performed and

the specific inspection findings identified are included in the following sections of the

report.

This inspection constituted 25 samples as defined in Inspection Procedure 71111.21-05.

3 Enclosure

.3 Component Design

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical

Specifications (TS), design basis documents, drawings, calculations and other available

design basis information, to determine the performance requirements of the selected

components. The inspectors used applicable industry standards, such as the American

Society of Mechanical Engineers (ASME) Code, Institute of Electrical and Electronics

Engineers (IEEE) Standards and the National Electric Code, to evaluate acceptability of

the systems design. The NRC also evaluated licensee actions, if any, taken in

response to NRC issued operating experience, such as Bulletins, Generic Letters (GLs)

Regulatory Issue Summaries (RISs), and Information Notices (INs). The review was to

verify that the selected components would function as designed when required and

support proper operation of the associated systems. The attributes that were needed for

a component to perform its required function included process medium, energy sources,

control systems, operator actions, and heat removal. The attributes to verify that the

component condition and tested capability was consistent with the design bases and

was appropriate may include installed configuration, system operation, detailed design,

system testing, equipment and environmental qualification, equipment protection,

component inputs and outputs, operating experience, and component degradation.

For each of the components selected, the inspectors reviewed the maintenance history,

system health reports, operating experience-related information, and licensee corrective

action program documents. Field walkdowns were conducted for all accessible

components to assess material condition and to verify that the as-built condition was

consistent with the design. Other attributes reviewed are included as part of the scope

for each individual component.

The following 16 components were reviewed:

reviewed the vendor manual, one-line diagram, equipment specification, and the

vendor nameplate rating to determine the diesel generator rated output

capability. The inspectors reviewed the EDG loading study for the worse case

design basis loading conditions. The inspectors reviewed the results of

surveillance tests to verify that the diesel generator test conditions enveloped

design basis and Technical Specification requirements. The inspectors also

reviewed normal and off-normal operating procedures to determine whether

appropriate load ratings and limitations were incorporated. The inspectors

reviewed selected pumps and fans to determine that break horsepower loads

were determined and based on conservative design and operating conditions.

The inspectors reviewed modification and corrective maintenance history to

determine whether any recent modifications or maintenance issues could

adversely impact diesel generator load capability. The inspectors conducted

walkdowns of the EDGs to determine the material condition and the operating

environment for indications of degradation of equipment.

4 Enclosure

  • 2400VAC (Volts Alternating Current) Essential Switchgear Breakers (152-105,

152-106, and 152-107): The inspectors reviewed the 2.4kV (kilovolt) 1C

essential switchgear breakers 152-105, 152-106 and 152-107 to verify they

would operate during design basis events. The inspectors reviewed breaker

opening and closure logic to verify the appropriate functionality was

implemented. The 125VDC (volts direct current) voltage calculations were

reviewed to determine if adequate voltage would be available for the breaker

open and close coils and spring charging motors. The inspectors also reviewed

the automatic and manual transfer schemes and logic between alternate offsite

sources and the EDG. Additionally, bus operating procedures were reviewed to

determine if adequate guidance was given to the operators to ensure design

basis assumptions were maintained. To determine if breakers were maintained

in accordance with industry and vendor recommendations, the inspectors walked

down the breakers to verify the as-built configuration and condition, and also

reviewed the associated preventive maintenance inspection and testing

procedures. In addition, the inspectors reviewed the non-safeguards information

related to the security modification for the addition of the Uninterruptible Power

Supplies (UPSs) to verify that the additional loading on the EDG was considered

and acceptable.

  • 125VDC Battery (ED-02): The inspectors reviewed electrical calculations for

safety-related 125VDC station battery ED-02. These included battery sizing and

loading calculations for safety-related direct current (DC) loads to verify that

adequate battery capacity was available during a design bases event and for a

station blackout event. The inspectors also reviewed the battery surveillance

tests and performance history to verify acceptance criteria were met and

performance degradation would be identified. Surveillance procedures were

verified to be in accordance with vendor guidance. The minimum and maximum

battery room temperatures were reviewed for consistency with design basis

requirements. The inspectors also reviewed battery chargers sizing calculations

and verified that battery chargers were periodically tested to ensure proper

operation. Operating procedures associated with the battery and its associated

chargers were also reviewed to ensure they were in accordance with vendor

recommendations. The inspectors also reviewed DC buses and DC panel

breakers associated with battery ED-02 to ensure that their short circuit

interrupting capability was adequate to for the available short circuit current.

  • Startup Transformer (1-1): The inspectors reviewed load flow conditions to

determine whether the transformer had sufficient capacity to support its required

loads under worst case accident loading conditions. The inspectors reviewed

transformer protective relaying and settings to determine whether there was

adequate protection. The inspectors reviewed the condition monitoring for the

transformer, bushings and lightning arrestors to determine whether it was

consistent with vendor and industry recommendations. A visual inspection of the

transformer and its auxiliaries was performed by the inspectors in order to assess

material condition. Finally, the inspectors reviewed maintenance records and

corrective action documents to determine whether there was an adverse

equipment operating trend.

5 Enclosure

turbine driven auxiliary feedwater pump to verify its capability of providing

makeup water to the steam generators. The inspectors reviewed the pump with

regard to net positive suction head (NPSH), minimum flow, overspeed, and

potential runout flow conditions. The inspection included a review of the

component licensing basis, calculations, and operating procedures related to

these functions. This included the automatic and manual pump control logic, the

turbine driver, and the steam supply system. The inspectors evaluated pump

operation during station blackout conditions, including room temperatures. In

addition, the inspectors reviewed pump suction pressure instrumentation. The

inspectors performed walkdowns of the auxiliary feedwater pump to verify the

material condition of the components. The inspectors reviewed surveillance test

procedures and test results. The inspectors also interviewed system and design

engineers regarding the pump and reviewed recent corrective actions.

  • Containment Air Coolers (VHX-1, VHX-2, and VHX-3): The inspectors reviewed

the safety-related containment air coolers to verify their capability of removing

heat under post-accident conditions. The inspectors reviewed the coolers with

regard to heat removal capability, potential fouling of the coolers, and the

potential of waterhammer during accident conditions. The inspection included a

review of the component licensing basis, calculations, and operating procedures

related to these functions. In addition, the inspectors reviewed the electrical

power requirements for the associated fans under accident conditions. The

inspectors also interviewed system and design engineers regarding the coolers

and reviewed recent corrective actions. The inspectors reviewed the results of

the load flow and voltage calculation to determine whether sufficient power was

available to start the motor during worst case degraded voltage and service

conditions. The inspectors reviewed the motor protection setting calculations to

determine whether there was adequate protection during degraded voltage

conditions. The inspectors reviewed the pump performance and brake

horsepower requirement to determine whether the motor was adequately sized

for the worst case load condition. Finally, the inspectors reviewed maintenance

and corrective action documents to determine whether the equipment has

exhibited adverse performance trends.

spray pump to verify its capability of providing post-accident containment cooling.

The inspectors reviewed the pump with regard to NPSH, minimum flow, and

potential runout flow conditions. The inspection included a review of the

component licensing basis, calculations, and operating procedures related to

these functions. This included the automatic and manual pump control logic.

The inspectors performed walkdowns of the auxiliary feedwater pump to verify

the material condition of the components. The inspectors reviewed surveillance

test procedures and test results. The inspectors also interviewed system and

design engineers regarding the pump and reviewed recent corrective actions.

The inspectors reviewed the results of the load flow and voltage calculation to

determine whether sufficient power was available to start the motor during worst

case degraded voltage and service conditions. The inspectors reviewed the

pump performance and brake horsepower requirement to determine whether the

motor was adequately sized for the worse case load condition.

6 Enclosure

A visual inspection of the motor was completed by the inspectors in order to

assess material condition and the motor nameplate data. Finally, the inspectors

reviewed maintenance and corrective action documents to determine whether

the equipment has exhibited adverse performance trends.

  • Containment Sump Isolation Valves (CV-3029 and CV-3030): The inspectors

reviewed the containment sump isolation valves to verify their capability of

providing containment isolation and opening when required under post-accident

conditions. The inspectors reviewed the valves with regard to opening under the

limiting conditions. The inspection included a review of the component licensing

basis, calculations, and operating procedures related to these functions. This

included the automatic and manual valve control logic and the air supply to these

valves. The inspectors performed walkdowns of the valves to verify the material

condition of the components. The inspectors reviewed surveillance test

procedures and test results. The inspectors also interviewed system and design

engineers regarding the valves and reviewed recent corrective actions.

  • EDG Fuel Oil Storage Tank (T-10A): The inspectors reviewed EDG fuel

consumption calculation and tank level instrumentation uncertainties to ensure

the tank has adequate diesel fuel oil capacity. The fuel oil monitoring limits were

reviewed to ensure adequate fuel oil quality. Design change history, corrective

actions, surveillance results, and trending data were reviewed to assess potential

component degradation and impact on design margins including TS volume

limits. The licensees evaluation of potential impact of the new ultra-low sulfur

diesel fuel oil (IN 2006-022) was reviewed. The inspectors performed visual

non-intrusive inspections to assess the installation configuration, material

condition, and potential vulnerability to hazards.

  • High Pressure Safety Injection Pump (P-66B): The inspectors reviewed the

system hydraulic calculations such as NPSH, vortexing, and waterhammer to

ensure that the pumps were capable of providing their accident mitigation

function. In addition, the inspectors reviewed completed pump surveillances to

ensure that actual performance was acceptable. The inspectors reviewed

vendor specifications and pump curves to make sure that these parameters had

been correctly translated into calculations, as required. The inspectors also

reviewed seal and bearing cooling capacity and the environmental qualification of

certain components required for pump availability. Design change history,

corrective actions, surveillance results, and trending data were reviewed to

assess potential component degradation and impact on design margins. The

inspectors performed visual non-intrusive inspections to assess the installation

configuration, material condition, and potential vulnerability to hazards. The

inspectors reviewed the results of the load flow and voltage calculation to

determine whether sufficient power was available to start the motor during worst

case degraded voltage and service conditions. The inspectors reviewed the

pump performance and brake horsepower requirement to determine whether the

motor was adequately sized for the worse case load condition. A visual

inspection of the motor was completed by the inspectors in order to assess

material condition and the motor nameplate data. Finally, the inspectors

reviewed maintenance and corrective action documents to determine whether

the equipment has exhibited adverse performance trends.

7 Enclosure

  • Service Water Pump (P-7A): The inspectors reviewed the system hydraulic

calculations such as NPSH and vortexing to ensure that the pumps were capable

of providing their accident mitigation function. In addition, the inspectors

reviewed completed pump surveillances to ensure that actual performance was

acceptable. The inspectors reviewed vendor specifications and pump curves to

make sure that these parameters had been correctly translated into calculations,

as required. Design change history, corrective actions, surveillance results, and

trending data were reviewed to assess potential component degradation and

impact on design margins. The inspectors performed visual non-intrusive

inspections to assess the installation configuration, material condition, and

potential vulnerability to hazards. The inspectors reviewed the results of the load

flow and voltage calculation to determine whether sufficient power was available

to start the motor during worst case degraded voltage and service conditions.

The inspectors reviewed the pump performance and brake horsepower

requirement to determine whether the motor was adequately sized for the worse

case load condition. A visual inspection of the motor was completed by the

inspectors in order to assess material condition and the motor nameplate data.

Finally, the inspectors reviewed maintenance and corrective action documents to

determine whether the equipment has exhibited adverse performance trends.

inspectors reviewed the air-operated valve (AOV) thrust calculation and

environmental qualification of valve actuator to ensure the valve was capable of

functioning under design conditions. Design change history, corrective actions,

surveillance results, and trending data were reviewed to assess potential

component degradation, impact on design margin, and that adequate air supply

was available. The inspectors performed visual non-intrusive inspections to

assess the installation configuration, material condition, and potential

vulnerability to hazards.

  • Component Cooling Water to SDC Heat Exchanger Valve (CV-0938): The

inspectors reviewed the AOV thrust calculation and environmental qualification of

valve actuator to ensure the valve was capable of functioning under design

conditions. Design change history, corrective actions, surveillance results, and

trending data were reviewed to assess potential component degradation, impact

on design margin, and that adequate air supply was available. The inspectors

performed visual non-intrusive inspections to assess the installation

configuration, material condition, and potential vulnerability to hazards.

  • SDC Heat Exchanger Discharge Valve (CV-3025A): The inspectors reviewed

the AOV thrust calculation and environmental qualification of valve actuator to

ensure the valve was capable of functioning under design conditions. Design

change history, corrective actions, surveillance results, and trending data were

reviewed to assess potential component degradation, impact on design margin,

and that adequate air supply was available. The inspectors performed visual

non-intrusive inspections to assess the installation configuration, material

condition, and potential vulnerability to hazards.

8 Enclosure

  • SDC/Low Pressure Injection Valve (MO-3016): The inspectors reviewed motor-

operated valve (MOV) calculations and analyses to ensure the valve was

capable of functioning under design conditions. This included calculations for

required thrust, maximum differential pressure, and valve weak link analysis. In

addition, the inspectors reviewed valve DC motor calculations to confirm that the

design basis minimum voltage at the motor terminals would be adequate for

starting and running, and protective device/thermal overload relay settings

provided adequate margin. The inspectors reviewed the control logic diagrams

to verify the proper functionality was implemented. Diagnostic and surveillance

results were reviewed to verify acceptance criteria were met and performance

degradation would be identified. The inspectors reviewed the calculation for the

voltage available at the motor terminals for technical adequacy and to determine

whether adequate voltage at the motor terminals exists during degraded voltage

conditions. The inspectors reviewed the schematic diagram for the motor power

circuit to determine the required elements for inclusion in the voltage analysis.

  • Atmospheric Dump Valve (CV-0781): The inspectors reviewed AOV calculations

and analysis to ensure the valve was functioning under design conditions. This

included calculations for required thrust. The inspectors also verified that the

pressure regulator set point was consistent with vender data. Condition reports

and surveillance results were reviewed to verify acceptance criteria were met and

performance degradation had been identified. In addition, the inspectors

reviewed operation procedures to verify that the component operation and

alignments were consistent with the design and licensing bases discussion. The

inspectors performed a walkdown to review the material condition of the valve

and reviewed the reliability of its back-up components.

b. Findings

(1) Inadequate Analysis of EDG 1-2 Loading During Design Basis Events

Introduction: The inspectors identified a finding of very low safety significance (Green)

and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, in

that the licensee had failed to evaluate the worst case design and procedurally allowed

manual loading conditions in calculating the EDG load during design basis events.

Description: The inspectors determined that the licensees calculated EDG 1-2 loading

during a design basis large loss-of-coolant-accident (LOCA) condition did not consider

worst case motor load conditions during automatic loading and also did not consider

security lighting loads that were manually loaded on the generator. Specifically, the

containment fan cooler motor loads considered in the EDG 1-2 loading analysis did

not represent the worst case design condition during a large LOCA, when the cooler

coils are partially flooded in the time period prior to recirculation actuation. In response

to the teams request for the containment fan cooler brake horsepower requirement,

the licensee found that the fan horsepower that was determined by calculation

EA-DPAL-93-110, which evaluated the containment air cooler air flow at flooded

condition, was not used as a design input in the EDG loading calculation

EA-ELEC-LDTAB-005. The fan load was calculated to be 72 horsepower for a partially

flooded cooler coil, but only 52.2 brake horsepower was included in the EDG load

calculation. The calculated net impact to EDG 1-2, was an additional 51.3 kW (kilowatt)

for the V-1A, V-2A and V-3A fan coil unit motors, which could result in loading the EDG

9 Enclosure

above the 2-hour 2750 kW rating. In addition, the licensee found during the inspection

that security procedures did not contain sufficient direction to prevent overloading of

EDG 1-2, in that procedures did not contain directions to obtain permission from the

control room prior to energizing security lighting when Bus 1D is being powered solely

from EDG 1-2. The security lighting that was manually energized would be in addition to

the automatic loading for the containment fan cooler motors, resulting in additional

loading above the 2-hour rating for EDG 1-2. These issues were entered into the

Palisades corrective action program as Condition Report CR-PLP-2008-04580 and

CR-PLP-2008-04747 respectively. The licensee took immediate corrective action during

the inspection to secure two (2) non-safety-related pumps on EDG 1-2, the Turbine

Generator Emergency Air Side Seal Oil Backup Pump (P-23) and the Turbine Turning

Gear Oil Pump (P-26), and the Alarm Station Operators were instructed not to turn on

the security lighting in the event that there was a loss-of-offsite-power (LOOP). These

actions resulted in the calculated EDG 1-2 automatic and manual loading to stay within

the 2-hour rating.

Analysis: The inspectors determined that the licensees failure to ensure the loads on

EDG 1-2 were below the 2-hour rating was a performance deficiency. Specifically,

containment cooler fan motor load was not considered for partial flooding of the cooling

coils, and manual loading of specific lighting loads on the EDG were not included in the

loading analysis.

The finding was more than minor because it was similar to NRC Inspection Manual

Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, Example 3.j, in that there

was a reasonable doubt on the operability of EDG 1-2, since EDG loading conditions

above the 2-hour rating were neither adequately calculated nor periodically tested. The

finding was associated with the design control attribute of the Mitigating Systems

cornerstone and affected the cornerstone objective of ensuring the availability, reliability

and capability of systems that respond to initiating events to prevent undesirable

consequences.

The inspectors determined the finding could be evaluated using the SDP in accordance

with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -

Initial Screening and Characterization of Findings, Table 4a for the Mitigating Systems

cornerstone. The finding screened as of very low safety significance (Green) because

the finding was a design or qualification deficiency confirmed not to result in loss of

operability or functionality. Specifically, the licensees historical operability evaluation,

CR-PLP-2008-04580 CA-03, that included the EDG vendors input, determined that

EDG 1-2 would have been operable or functional for the worst case loading conditions.

The inspectors did not identify a cross-cutting aspect associated with this finding

because the performance deficiency was related to a historical design issue and not

indicative of current licensee performance.

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, required,

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, in June 1993, the licensee failed to evaluate the worst case

design loading and procedurally allowed manual loading conditions when determining

10 Enclosure

the emergency diesel generator load required for design basis loss-of-coolant-accident

and loss-of-offsite-power conditions. Specifically, the licensee failed to assure that

EDG 1-2 would not be loaded above the 2-hour rating for the fan cooler motor loads

during a Large LOCA and also for the security lighting loads that are manually energized

during a LOOP condition. Because this violation was of very low safety significance and

it was entered into the licensees corrective action program as CR-PLP-2008-04580 and

CR-PLP-2008-04747, this violation is being treated as an NCV, consistent with

Section VI.A.1 of the NRC Enforcement Policy (NCV 05000255/2008009-01).

(2) Failure to Establish Correct TS Limits

Introduction: A finding of very low safety significance and associated NCV of 10 CFR

Part 50, Appendix B, Criterion III, Design Control, was identified by the inspectors for

the failure to incorporate the appropriate EDG load profile when establishing the TS limit

for the EDG day tank fuel oil volume which assured the allowed outage time of the

limiting fuel oil transfer pump.

Description: On November 18, 2008, the inspectors identified that the licensee failed to

incorporate the appropriate load profile when calculating the EDG fuel oil consumption.

This failure resulted in the establishment of a non-conservative TS limit for the EDG day

tank fuel oil volume that did not support the allowed outage time of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for the

limiting fuel oil transfer pump.

Specifically, TS 3.8.3, Diesel Fuel, Lube Oil, and Starting Air, allowed an outage time of

15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> for the fuel oil transfer pump P-18A. This outage time was based on the

amount of fuel available in the day tank to support the operation of the EDG associated

with P-18A if dependent on offsite power or the redundant EDG beyond the run time

supported by the day tank. Therefore, the 15-hour allowed outage time did not meet the

requirement for independence during this condition. In a letter dated June 27, 1997,

from Palisades Nuclear Plant to the NRC, it was stated that each fuel oil day tank

contained sufficient fuel for more than 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> at full load. However, the inspectors

noted that the TS limit of 2500 gallons was based on fuel oil consumption for the EDG at

actual load instead of the fuel oil consumption for the EDG at full load.

Upon further review, the licensee agreed that the TS limit of 2500 gallons was

insufficient to support an EDG run time of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> at full load. It was later determined

that this volume was sufficient to support a run time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As a result, the

licensee implemented compensatory measures to administratively limit the allowed

outage time for P-18A to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This administrative control has been implemented as

a standing order in accordance with procedure EN-OP-112, Night and Standing

Orders. In addition to implementing the compensatory measure, the licensee

documented the need for a license amendment to resolve the non-conservative TS

Surveillance Requirement SR 3.8.3.C.1 in their Regulatory Horizons data base.

Analysis: The inspectors determined that the failure to establish adequate TS limits for

the EDG day tanks fuel oil volume to support the P-18A fuel oil transfer pump allowed

outage time was a performance deficiency. The performance deficiency was determined

to be more than minor in accordance with IMC 0612, Power Reactor Inspection

Reports, Appendix B, Issue Disposition Screening, because the finding was

associated with the Mitigating Systems cornerstone attribute of equipment performance

and affected the cornerstone objective of ensuring availability of the EDG to respond to

11 Enclosure

initiating events to prevent undesirable consequences. Specifically, the TS fuel oil limit

for the day tanks was insufficient to support the EDG associated with fuel oil transfer

pump P-18A during the pumps 15-hour allowed outage time.

The inspectors determined the finding could be evaluated using the SDP in

accordance with IMC 0609, Significance Determination Process, Attachment 0609.04,

Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigating

Systems cornerstone. The finding screened as of very low safety significance (Green)

because the finding was a design or qualification deficiency confirmed not to result in

loss of operability or functionality. Specifically, a historical review was conducted of fuel

oil transfer pump outages, and it was determined that adequate fuel was always

available in the day tanks.

The inspectors did not identify a cross-cutting aspect associated with this finding

because the performance deficiency was related to a historical design issue and not

indicative of current licensee performance.

Enforcement: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires

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, since 1997, the licensee failed to correctly translate applicable

design basis into specifications. Specifically, design control measures (calculations)

failed to incorporate the appropriate load profile when establishing the TS limit for the

day tanks 15-hour fuel oil volume requirement that supported the TS allowable outage

time for fuel oil transfer pump P-18A. Because this violation was of very low safety

significance and it was entered into the licensees corrective action program as

CR-PLP-2008-04708, this violation is being treated as an NCV, consistent with

Section VI.A.1 of the NRC Enforcement Policy (NCV 05000255/200809-02).

(3) Non-Safety-Related Components Credited in Steam Generator Tube Rupture Accident

Analysis

Introduction: The inspectors identified an unresolved item regarding the

non-safety-related atmospheric dump valves (ADVs) credited in the UFSAR

(Chapter 14) analysis of the steam generator tube rupture (SGTR) accident.

Description: As part of the review of ADV CV-0781, the inspectors reviewed operation

procedures to verify that the component operation and alignments were consistent with

the design and licensing bases discussion. During this review, the inspectors identified

that in the UFSAR (Chapter 14) analysis of the SGTR accident, the maximum off-site

dose release for the SGTR accident was based on the non-safety-related ADVs being

functional and capable of terminating the accident release.

The inspectors noted that during a LOOP condition, the non-safety-related air supply to

the ADV actuator might not be available. Therefore, the inspectors requested the

licensee to identify safety-related components that could be used to mitigate a release in

a SGTR event without crediting the ADVs. The licensee indicated that if both the ADVs

and the turbine bypass valves are unavailable, EOP-5.0, Steam Generator Tube

Rupture Recovery, directed operators to use the strategy of once through cooling that

12 Enclosure

utilized safety-related components, the pressurizer power operated relief valves and the

high pressure safety injection system.

Pertaining to the UFSAR (Chapter 14) SGTR analysis, the licensee indicated that the

accident analysis evaluated the bounding scenario in which the ADVs were used for

cool-down. However, the UFSAR analysis did not address the use of once through

cooling to mitigate this event. The inspectors requested the licensee provide

documentation confirming that the use of the non-safety-related ADVs to mitigate a

SGTR accident was reviewed by NRC staff and accepted in a safety evaluation report or

other correspondence. By the end of the inspection, the licensee had not identified a

document demonstrating NRC staff had specifically reviewed and accepted the use of

non-safety-related ADVs to mitigate a SGTR accident.

The inspectors discussed this design and licensing basis issue with NRC staff in the

Office of Nuclear Reactor Regulation. Due to complexity of establishing the appropriate

design and licensing bases for this issue, the concern will be resolved using the NRCs

Task Interface Agreement (TIA) process. Pending resolution, this item will be tracked as

an unresolved item (URI 05000255/2008009-03).

.4 Operating Experience

a. Inspection Scope

The inspectors reviewed four operating experience issues to ensure that NRC and

industry generic concerns had been adequately evaluated and addressed by the

licensee. The operating experience issues listed below were reviewed as part of this

inspection:

  • IN 2006-03, Motor Starter Failure Due to Mechanical Interlock Binding;

Engine Performance;

  • IN 2006-31, Inadequate Fault Interrupting Rating of Breakers; and
  • IN 2007-34, Operating Experience Regarding Electric Circuit Breakers.

b. Findings

No findings of significance were identified.

13 Enclosure

.5 Modifications

a. Inspection Scope

The inspectors reviewed three permanent plant modifications related to selected

risk-significant components to verify that the design bases, licensing bases, and

performance capability of the components had not been degraded through modifications.

The modifications listed below were reviewed as part of this inspection effort:

  • EC 8290, Install Supplemental 2400V Diesel Generator and Circuit Breaker

152-403;

b. Findings

No findings of significance were identified.

.6 Risk-Significant Operator Actions

a. Inspection Scope

The inspectors performed a margin assessment and detailed review of five

risk-significant operator actions. These actions were selected from the licensees PRA

rankings of human action importance based on risk achievement worth values. Where

possible, margins were determined through a review of the assumed design basis and

UFSAR response times and performance times documented by job performance

measures results and by PRA analysis assumed operator response times. For the

selected operator actions, the inspectors performed a detailed review and walk

through of associated procedures, and observed two operating crews perform several

risk-significant operator actions during simulator scenarios. The inspectors also

performed in plant observations for other important operator actions with a qualified

senior reactor operator and an equipment operator to assess licensed operator and

non-licensed operator knowledge level, adequacy of plant procedures, and the

availability of special equipment required to perform the risk-significant operator actions

out in the plant.

The following operator actions were reviewed:

  • Operator Actions for Initiation of Once Through Cooling;
  • Operator Actions following Loss of Primary Cooling Pump Seal Cooling;
  • Operator Actions to Enable ESS Recirculation Valve to Close on Recirc Actuation

Signal; and

  • Operator Actions to Close ADV Manual Block Valve.

14 Enclosure

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered Into the Corrective Action Program

a. Inspection Scope

The inspectors reviewed a sample of the selected component problems that were

identified by the licensee and entered into the corrective action program. 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,

corrective action documents written on issues identified during the inspection were

reviewed to verify adequate problem identification and incorporation of the problem into

the corrective action program. The specific corrective action documents that were

sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Meeting(s)

.1 Exit Meeting Summary

On December 4, 2008, the inspectors presented the inspection results to

Mr. C. Schwarz, and other members of the licensee staff. The licensee acknowledged

the issues presented. The inspectors asked the licensee whether any materials

examined during the inspection should be considered proprietary. Several documents

reviewed by the inspectors were considered proprietary information and were returned to

the licensee.

ATTACHMENT: SUPPLEMENTAL INFORMATION

15 Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

C. Schwarz, Site Vice PresidentA. Blind, Design Engineering Manager

J. Broschak, Site Engineering Director T. Davis, Licensing

B. Dotson, Regulatory Affairs

J. Erickson, Licensing

W. Ford, Maintenance Manager

T. Groth, Design Engineering

G. Katt, System Engineering

B. Kemp, Design Engineering Supervisor

D. Kennedy, Electrical I&C Design Engineer

T. Kirwin, Plant General Manager

L. Lahti, Regulatory Affairs Manager

D. MacMaster, Design Engineering

B. Meredith, System Engineering

R. Moceri, System Engineering

B. Nixon, Training Manager

M. Nordin, Configuration Management Supervisor

M. Richey, Planning, Scheduling, and Outage Manager

P. Russell, Systems Engineering Manager

M. Sicard, Operations Manager

G. Sleeper, Operations

B. Sova, Electrical I&C Engineering Supervisor

B. VanWagner, Engineering Programs Manager

R. Westerhof, Mechanical Engineering Supervisor

R. White, Operations

Nuclear Regulatory Commission

D. Hills, Chief, Engineering Branch 1, (DRS)

A. M. Stone, Chief, Engineering Branch 2, (DRS)

J. Ellegood, Senior Resident Inspector

T. Taylor, Resident Inspector

1 Attachment

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

05000255/2008009-01 NCV Inadequate Analysis of Emergency Diesel

Generator 1-2 Loading During Design Basis Events

(1R21.3.b.(1))05000255/2008009-02 NCV Failure to Establish Correct Technical Specification

Limits (1R21.3.b.(2))05000255/2008009-03 URI Non-Safety-Related Components Credited in Steam

Generator Tube Rupture Accident Analysis

(1R21.3.b.(3))

Closed

05000255/2008009-01 NCV Inadequate Analysis of Emergency Diesel

Generator 1-2 Loading During Design Basis Events

(1R21.3.b.(1))05000255/2008009-02 NCV Failure to Establish Correct Technical Specification

Limits (1R21.3.b.(2))

Discussed

None

2 Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

CALCULATIONS

Number Description or Title Revision

1 PRA Time Dependent Scenario Validation Package: ---

PRA Enable Closure of the ESS Valves on a RAS

14 PRA Time Dependent Scenario Validation Package: ---

Alignment of Charging for SGTR

2 PRA Time Dependent Scenario Validation Package: ---

Match PCS and Steam Generator During a SGTR

event

24 PRA Time Dependent Scenario Validation Package: ---

Operator Fails to Isolate Faulted SG During SGTR

3 PRA Time Dependent Scenario Validation Package: ---

Maintain Adequate AFW to the Unaffected SG

During a SGTR

4 PRA Time Dependent Scenario Validation Package: ---

Initiation of OTC

52-1208, Containment Cooler Recirculation Fan V1A 3

Sh. 11-12/8A

52-1209, Containment Cooler Recirculation Fan V2A 3

Sh. 11-12/7A

52-1210, Containment Cooler Recirculation Fan V3A 3

Sh. 11-12/7B

7 PRA Time Dependent Scenario Validation Package: ---

Manual Control of AFW Flow

8 PRA Time Dependent Scenario Validation Package: ---

Manually Isolate a Failed Open ADV

C-PAL-94-0130 Prevention of waterhammer in SI bottle lines 04/20/95

EA- AOVT/T-CCS-04 Evaluation of Stem Torque Requirements For 2

Palisades AOV(s) CV-0937 and CV-0938 Using The

EPRI MOV Butterfly Valve Performance Prediction

Methodology

EA-AFW-CA016278 Analysis of Auxiliary Feedwater System Parameters 1

when Cross-Connected to the Fire Protection System

using Pipe-Flo

EA-AOV-09 Engineering Analysis for Operability of CV-3029, CV- 0

3030, CV-3031, and CV-3057

EA-AOV-10 Palisades High Pressure Air Solenoid Valve Testing 0

3 Attachment

CALCULATIONS

Number Description or Title Revision

EA-AOVCAP-GATE- Actuator Capability Review for Air Operated Gate 1

ESS-01 Valves in the Engineered Safeguards System (ESS)

EA-AOVCAP-MSS-01 Actuator Capability Review for Air Operated Valves 1

with Reverse Acting Fail Closed Diaphragm

EA-AOVSYS-ESS-1 System Level Design Basis Review for Air Operated 7

Valves (AOV) in the Engineered Safeguards System

(ESS)

EA-AOVT/T-Double-01 Thrust requirements for Palisades double seat globe 1

valves

EA-AOVT/T-ESS-3 Evaluation of Stem Thrust Requirements for AOVs 0

CV-3029 & CV-3030

EA-AOV-WKLINK-06 Weak Link Calculation for AOVs CV-3029 and CV- 1

3030 from

Crane Valves

EA-A-PAL-86-148-01 Heating Ventilation Air Conditioning (HVAC) 2

Appendix R Damage to Alternate Shutdown

Equipment

EA-A-PAL-94-095 Auxiliary Feedwater Pumps Net Positive Suction 0

Head

EA-A-PAL-94-279-009 Seismic Analysis and Weak Link Calculation for 12 0

Bolted Bonnet Gate Valve

EA-APR-96-004 Appendix R Periodic Review to Asses Drawing 0

Impacts on Safe Shutdown Circuit Analysis

EA-BWH-97-001 Evaluation of P-8A/B/C Full Flow Data and 0

Establishment of P-8A/B Inservice Testing Reference

Values/Acceptance Limits

EA-C-PAL-95-0053B-01 Incorporation of a Higher Auxiliary Feedwater Pump 2

Low Suction Pressure Trip Setpoint into the T-2/T-81

Inventory Calculations Using the RETRAN Program

EA-C-PAL-95-0877D Evaluation of potential of excessive air entrainment 0

caused by vortexing in the SIRWT during a LOCA.

EA-C-PAL-96-0837A-01 Analysis of fuel volume of the EDG belly tank at the 0

sump start fill level switch setpoint

EA-C-PAL-96-0883-01 Containment Spray Pump Runout and Impact of Low 0

Flow Rates on Pump

EA-C-PAL-97-1650A-01 Revised Hydraulic Inputs for Emergency Diesel 2

Generator Steady State Load Calculation

EA-C-PAL-99-1209B-01 Generation of flow rate acceptance criteria for TS 1

surveillance test RO-216

EA-DAB-90-01 K-8/P8-B Flow and Pressure at Turbine Trip Speed 0

EA-DPAL-93-110 Containment Air Cooler Air Flow Evaluation At 0

Flooded Condition

EA-D-PAL-93-110 Containment Air Cooler Air Flow Evaluation at 0

Flooded Condition

4 Attachment

CALCULATIONS

Number Description or Title Revision

EA-D-PAL-93-272A-00- Allowed Degradation for Containment Spray Pumps 0

16-01 in ASME XI Pump Testing

EA-EAR-2001-0333-01 Generation of ESS pump performance curves for use 3

with the Pipe-Flo ESS Hydraulic Model

EA-EAR-96-0204-01 Documentation of T-25A and T-25B level transmitter 3

calibration values and worst case low level alarm

setpoint

EA-EC10838-01 Allowable Time for Operating HPSI Pump with no 0

CCW Cooling

EA-EC-235-01 Assessment of the High Pressure Air Systems 0

Capability to Cycle Valves in the West Engineering

Safeguards

EA-EC6432-01 Palisades EDG Diesel Fuel Oil Storage 0

Requirements

EA-ELEC-AMP-025 Battery Charger ED-15, 16, 17, 18 Output Current 1

Required to Recharge Batteries ED01 and Ed-02

EA-ELEC-FLT-005 Short Circuit for the Palisades Class 1E Station 1

Batteries D01 and D02

EA-ELEC-LDTAB-005 Emergency Diesel Generators 1-1 & 1-2 Steady 8

State Loading

EA-ELEC-LDTAB-009 Battery Sizing for The Palisades Class 1E Station 3

Batteries D01 and D02

EA-ELEC-VOLT-026 Voltage Drop Model for the Palisades Class 1E 1

Station Batteries D01 and D02

EA-ELEC-VOLT-037 Palisades Degraded Voltage Calculation For The 3

Safety-Related MOVs

EA-ELEC-VOLT-052 DC Control Circuit Minimum Required Voltage 0

Analysis

EA-FC-842-01 Input/Output EA for FC-842 AFW Pumps P-8A, P-8B, 0

and P-8C Control System Upgrade

EA-FC-951-01 Containment Cooling Load Evaluation for 0

Replacement Cooling Coil

EA-FC-951-03 Code Reconciliation for Replacement Containment 0

Air Coolers, Piping, Pipe Supports, and Coil Supports

EA-FC-951-04 New Containment Air Cooler Inlet/Outlet Pipe Size 2

Verification

EA-FC-951-05 Structural Adequacy of Cooler Housing 2

EA-FC-951-06 Coil Support Frame/Cart Design 1

EA-FC-951-08 Containment Air Cooler Performance Codes for the 0

Replacement Air Coolers (Aerofin Coils)

EA-FC-951-09 Replacement Air Cooler Performance 0

EA-FC-954-02 Low Pressure Suction Trip on the Auxiliary 3

Feedpump - Setpoint Change

5 Attachment

CALCULATIONS

Number Description or Title Revision

EA-FC-958-03 EDG diesel fuel oil transfer system requalification - 1

electrical instrumentation

EA-FC-958-04 Calculation to size and provide instrumentation levels 2

for the replacement of the diesel fuel oil tank T-10

with T-10A

EA-FC-966-01 Mechanical Design Basis Analysis for AFW Steam 3

Supply (CV-0522A & B) - Modification FC-966

EA-GEJ-96-06 Minimum Aux. Feed Requirement for All Aux. Feed 0

Pumps

EA-GL-96-06-SWS-01 Calculation of GL 96-06 Water Hammer Loads in 0

Containment Air Cooler Service Water Piping Using

Pipe-Flo

EA-GL-96-06-SWS-02 Service water GL 96-06 waterhammer assessment 0

EA-GOTHIC-AFW-01 Auxiliary Feedwater Pump Room Heat Up Analysis 0

EA-MOD-2005-004-03 ESS Flow Rates & Pump NPSH during Recirc Mode 1

with CSS Throttling

EA-MOV-KALSI-001 Kalsi Engineering Thrust Rating Increase of the Limit 0

torque Actuators

EA-MOV-SIG-0499 Safety Significance Determination of Active MOVs in 0

the IPE Model and Results

EA-PIPEFLO-CSS-01 Containment Spray System Model Using Pipe-Flo 0

EA-PIPEFLO-ESS-01 Integrated Pipe-Flo Hydraulic Model of the 2

Containment Spray, High and Low Pressure Safety

Injection Systems

EA-PLTB-01 Evaluation of the Containment Sump Outlet Gate ---

Valves CV-3029 and CV-3030 for Susceptibility to

Pressure Locking and Thermal Binding

EA-PLTB-02 Pressure Locking Thermal Binding Evaluation for 0

SDC Return Valves MO-3015 and MO-3016

EA-RSW-94-002 Containment Spray Pump Differential Pressure 1

Indication Uncertainty

EA-SC-87-156-01 Increase the Operator Air Pressure for Auxiliary 1

Feedwater Pump Flow Control Valves and Change

the Time Delay for AFW Pump Start

EA-SC-87-156-02 Examination of Effects of Delay in Achieving Full 0

AFW System Flow

EA-SC-88-185-02 Evaluation of Change in SIRWT and Containment 0

Sump Valve Stroke Overlap

EA-SC-90-083-01 Change K-8 Turbine to Class II (675 psi/650 deg F) 3

EA-SDW-94-003 Special Test T-344 Results Confirmation and 0

RETRAN Model Verification

EA-SDW-95-001 Generation of minimum and maximum HPSI/LPSI 2

system performance curves using Pipe-Flo

6 Attachment

CALCULATIONS

Number Description or Title Revision

EA-SDW-95-003 Maximum Containment Spray Flow Rates Using 0

Pipe-Flo

EA-SWS-M-6-1 Acceptance Criteria for Leak Testing the 0

Containment Coolers

EA-T-223-1998-01 Evaluation of Special Test T-223 and CCW System 0

Analysis Under Varied Operating Conditions Using

Pipe-Flo

JCW-94-017 SI tank discharge line operability due to water 10/10/94

hammer concern

SP-03312 Piping stress analysis 02/25/93

SUT1-1/CO4/450- SUT 1-1 345KV Phase Overcurrent Relays 12/17/84

451S1

SUT1-1/CO4/451SN1 SUT 1-1 345KV Neutral Ground Relay 12/17/84

SUT1-1/CO4/487S1 SUT 1-1 Differential Relays 12/18/84

CORRECTIVE ACTION PROGRAM DOCUMENTS

Number Description or Title Date

A/R 01018863 Quality Programs with SBO Compliance ---

A/R 01018863 Apparent Cause Report. Quality Classification of SBO 04/17/06

Components

CR-PLP-2003- Documentation Inconsistencies for the Atmosphere Steam 01/28/03

00572 Dump

CR-PLP-2006- Quality Programs with SBO Components 03/16/06

01184

CR-PLP-2007- Uncompleted recommendation from old CR to prevent 04/19/07

01637 waterhammer in the SI lines

CR-PLP-2007- CV-3025 conduit support clamp has fallen off support bracket 09/18/07

04122

CR-PLP-2007- Issues related to EDG fuel oil tank volume calculations 09/21/07

04259

CR-PLP-2008- Overly restrictive stroke time requirements associated with 06/13/08

02646 operability of CV-3025 & Cv-3055

CR-PLP-2008- Bolt Broken Off On Space Heater Cover On The Generator for 10/20/08

04318 the 1-2 Emergency Diesel Generator

CR-PLP-2008- West safeguards door 59 was difficult to latch 11/05/08

04542

CR-PLP-2008- Potential loss of diesel fuel oil transfer pumps due to spray 11/06/08

04546 from circulating water pipe

CR-PLP-2008- NRC Identified 2 Fire Brigade Lockers with Missing Seals 11/06/08

04550

CR-PLP-2008- Rusty Spring in Support HB23-H282 (Service Water Supply 11/07/08

04572 Header between Control Valves CV-0846 and CV-0857)

7 Attachment

CORRECTIVE ACTION PROGRAM DOCUMENTS

Number Description or Title Date

CR-PLP-2008- Potential Impact of Emergency Diesel Generator 11/07/08

04573 Intake/Exhaust Room Temperature

CR-PLP-2008- Evaluate Impact of EDG Intake/Exhaust Room Temperature 11/07/08

04573

CR-PLP-2008- D/G load calc did not account for worst case load from CAC 11/07/08

04580 fan motors (Reportable to NRC 8-hr and LER)

CR-PLP-2008- Discrepancy Between Calculation EA-ELEC-LDTAB-009 and 11/18/08

04690 EOP Supplement 8

CR-PLP-2008- EDG allowable water level in T-10A potentially not 11/19/08

04707 conservative.

CR-PLP-2008- Emergency Diesel Generator Fuel Consumption Rate 11/19/08

04708

CR-PLP-2008- Non-conservative EDG fuel consumption rate used in diesel 11/19/08

04708 fuel oil storage calculation.

CR-PLP-2008- As-found service water flow did not meet acceptance criteria 11/20/08

04739 was not captured in the corrective action program

CR-PLP-2008- Security Procedures did not Contain Guidance to Obtain 11/21/08

04747 Control Room Permission Before Manually Turning on

Security Lighting when Bus 1D is being Powered Solely from

EDG 1-2

CR-PLP-2008- Minor calculation error in EA-C-PAL-94-0130-01 12/01/08

04853

CR-PLP-2008- Calculation Deficiencies Associated with Station Battery 12/04/08

04913 Chargers

CR-PLP-2008- Discrepancy Between Calculation EA-ELEC-FLT-005, 12/09/08

04972 Revision 1 and FSAR Table 8-5

DRAWINGS

Number Description or Title Revision

05901, Sheet 1 Aux. Feedwater Pump Suction 7

E-1 Sheet 1 Single Line Meter & Relay Diagram - 480 Volt Motor 79

Control Center Warehouse

E-1, Sh. 1 Single Line Meter & Relay Diagram 480 Volt Motor Control 79

Center Warehouse

E-1, Sh. A Single Line Meter and Relay Diagram 9

E-132 Sheet 1 Schematic Diagram - Start-up Transformer 1-1 & 1-2 25

Incoming Breakers

E-17 Sheet 17 Logic Diagram - Generator Breaker and M.O.D Control 3

E-242, Sh. 3 Schematic Diagram Vol. Control Shutdown Cooling & 23

Press. Relief Motor Oper. Valves

E-8 sheet 2 Single Line Meter & Relay Diagram - 125 VDC 51

VEN-M-101 Stress Isometric - Auxiliary Feedwater Pump Suction 6

8 Attachment

DRAWINGS

Number Description or Title Revision

WD1421, Sh. 31 Palisades Substation M

10 CFR 50.59 DOCUMENTS (SCREENINGS/SAFETY EVALUATIONS)

Number Description or Title Revision

06-0162 Replace Containment Spray Isolation Valves per GSI- 0

191 Resolution

07-0007 Replace Containment Spray Isolation Valves per GSI- 1

191 Resolution

QF-0501(FP-E-SE- Atmospheric Dump Valves (ADVs) 02/24/05

03)

Screening 07-0078 Disable Fast Transfer 0

SDR-99-0658 Evaluation of Special Test T-223 and CCW System 0

Analysis Under Varied Operating Conditions Using

Pipe-Flo

MISCELLANEOUS

Number Description or Title Date or

Revision

5935-M-12 Specification For The Emergency Diesel Generators 12/12/68

Palisades Plant Consumers Power Company

5935-M-12 Part II - Technical Data for Emergency Diesel Generators 10/23/68

DBD-1.03 Design Basis Document - Auxiliary Feedwater System 7

DBD-1.05 Design Basis Document - Compressed Air Systems 4

DBD-2.03 Design Basis Document - Containment Spray System 7

DBD-2.08 Design Basis Document - Containment Air Coolers 3

DBD-5.01 Design Basis Document Diesel Engine And Auxiliary 5

Systems

DBD-5.03 Design Basis Document Emergency Diesel Generator 7

Performance Criteria

DBD-7.01 Palisades Plant EEQ Environments, App A 5

Docket No. 50-255 NUREG-0820 Integrated Plant Safety Assessment 08/82

Docket No. 50-255 NUREG-0820 Integrated Plant Safety Assessment 11/83

F-CG-90-087 CCP discrepancy report 02/07/91

G727-0284 ALCO Products Inc. Load Test Data Order No. 35226 #1 07/24/69

G727-0285 ALCO Products Inc. Load Test Data Order No. 35226 #1 07/24/69

G727-0296 ALCO Products Inc. Load Test Data Order No. 35226 #2 08/01/69

G727-0297 ALCO Products Inc. Load Test Data Order No. 35226 #2 08/01/69

N/A Worthington Corporation Letter to Bechtel Corporation, 11/26/68

Your Inquiry 5935M12, Our Proposal SF246/SMW1201,

Emergency Diesel Generators Consumers Power Co.

9 Attachment

MISCELLANEOUS

Number Description or Title Date or

Revision

N/A NMC Letter to Fairbanks & Morse Alco Engines, Mr. Ted 02/15/07

Stevenson from Mr. Greg Brock, Palisades Nuclear Plant

N/A TS change request - electrical power systems, additional 06/27/97

information

N/A Potential for steam-water waterhammer in the Palisades 12/03/08

Injection Piping

N/A Air entrainment centrifugal pumps general guidelines 11/20/06

N/A Air entrainment AFW pumps 01/10/07

N/A Resolution of GL 96-06 waterhammer issues 08/18/04

N/A Palisades Nuclear Plant Fire Hazards Analysis 7

NRC Letter Issuance of Amendment - Re: Backup Steam Supply for 3/14/00

Turbine-Driven Auxiliary Feedwater Pump P-8B

NRC Letter Notice of Enforcement Discretion - Re: Backup Steam 2/18/00

Supply for Turbine-Driven Auxiliary Feedwater Pump P-8B

SL-5578 Evaluation of Containment Cooler Control Valve Bypass 0

Flow

UFSAR Chapter Steam Generator Tube Rupture With a Loss of Offsite 23

14.15 Power

MODIFICATIONS

Number Description or Title Date or

Revision

EC 10519 Make Temporary Mod EC8290 (Install Supplemental 2400V 0

DG and Circuit Breaker 152-403) Permanent

EC 12118 EDG run time from day tank 12/02/08

EC 8290 Addition of Supplemental Diesel Generator (SDG) & Breaker 0

152-403 at Safeguards Bus A14, Cubicle 4

EC 8350 Replace Containment Spray Isolation Valves per GSI-191 0

Resolution

EC-9610 Evaluate Operation of the Site Diesel Fuel Burning Equipment 04/12/06

with Diesel Fuel with Sulfur Content Less than 15ppm (Ultra

Low Sulfur Diesel Fuel)

FC-944 ASDV Back-up Nitrogen Supply 9/28/93

OPERABILITY EVALUATIONS

Number Description or Title Date or

Revision

CR-PAL-2008- Emergency Diesel Generator Fuel Consumption Rate 12/09/08

04708

10 Attachment

OPERABILITY EVALUATIONS

Number Description or Title Date or

Revision

CR-PLP-2008- Emergency Diesel Generator Load Calculation Did Not 1

04580 Account For Worst Case Load From The Containment Air

Cooler Fan Motors (V-1A, V-2A and V-3A)

CR-PLP-2008- Past Operability Review for 1-2 EDG 12/22/08

04580 CA 3

EC 12279 CR on Table 8-5 of the FSAR 12/09/08

PROCEDURES

Number Description or Title Revision

COP-22A Diesel Fuel Oil Testing Program 9

COP-22A Diesel Fuel Oil Testing Program 7

EN-DC-167 Classification of Structures, Systems, and Components 2

EN-DC-195 Margin Management 3

EN-LI-100 Process Applicability Determination 7

EN-OP-102 Protective and Caution Tagging 10

EN-OP-104 Operability Determinations 3

EOP Supplement 12 A SG SGTR Isolation Checklist 7

EOP Supplement 13 B SG SGTR Isolation Checklist 7

EOP Supplement 17 A SG ESDE Isolation Checklist 6

EOP Supplement 18 B SG ESDE Isolation Checklist 6

EOP Supplement 28 Supplementary Actions For Loss of Power 9

EOP Supplement 42 Pre and Post RAS Actions 7

EOP Supplement 8 Battery #2 Load Stripping 5

EOP Supplement 8 Battery #2 Load Stripping 5

EOP-4.0 Loss of Coolant Accident Recovery 18

EOP-5.0 Steam Generator Tube Rupture Recovery 14

EOP-5.0 Steam Generator Tube Rupture Recovery 14

EOP-6.0 Excess Steam Demand Event 16

EOP-7.0 Loss of All Feedwater Recovery 13

MGSO-1 Nitrogen/Air Backup Station Bottle Replacement 12

MO-7A-1 and 2 Emergency Diesel Generators 1-1 & 1-2 12

MO-7A-2 Technical Specification Surveillance Procedure 67

Emergency

Diesel Generator 1-2

MSM-M-57 Universal Diagnostic System Operating Procedure 8

MSM-M-57 Universal Diagnostic System Operating Procedure 8

MSM-M-58 Diagnostic Procedure for AOV/MOV Testing 5

ONP-2.1 Off Normal Procedure Loss of AC Power 13

11 Attachment

PROCEDURES

Number Description or Title Revision

ONP-20 Off Normal Procedure Diesel Generator Manual 23

Control

ONP-6.2 Loss of Component Cooling 10

QO-02 Recirculation Actuation System 35

QO-16 Containment Spray Pumps 27

QO-21 Auxiliary Feedwater System 34

RO-128-2 Technical Specification Surveillance Procedure 14

Emergency

Diesel Generator 1-2 24-Hour Load Run

SOP-12 Feedwater System 54

SOP-19 Instrument Air System 46

SOP-20 High Pressure Control Air System 25

SOP-22 Emergency Diesel Generators 45

SOP-22 System Operating Procedure Emergency Diesel 45

Generators

SOP-3 Safety Injection And Shutdown Cooling System 75

SOP-4 Containment Spray System 24

SOP-5 Containment Air Cooling and Hydrogen Recombining

26

System

SOP-8 Main Turbine and Generating Systems 75

SPS-E-20 Maintenance for 2400 Volt Siemens Switchgear 3

T-278-1 Nitrogen Station No. 1 Performance Test 4

WI-FOS-I-01 Calibration of T-10A remote level indication instrument 5

SURVEILLANCES (COMPLETED)

Number Description or Title Date

MO-7A-2 Technical Specification Surveillance Procedure Emergency 08/18/08

Diesel Generator 1-2 (WO 51671765-01)

MO-7A-2 Technical Specification Surveillance Procedure Emergency 09/15/08

Diesel Generator 1-2 (WO 51676751-01)

QO-02 Recirculation Actuation System 5/98 -

10/07

QO-16 Containment Spray Pumps 12/07 -

10/08

QO-21 Auxiliary Feedwater System 2/07 -

8/08

RO-128-2 Technical Specification Surveillance Procedure Emergency 04/16/07

Diesel Generator 1-2 24-Hour Load Run (WO 00303648-01)

RO-128-2 Technical Specification Surveillance Procedure Emergency 10/21/08

Diesel Generator 1-2 24-Hour Load Run (WO 51658738-01)

12 Attachment

TRAINING DOCUMENTS

Number Description or Title Date

PL-IOTF Off-Normal Procedures 4

PL-ISIA LP: Main Steam System 14

PL-OPS-ONP SEG-001S: ONP-6.2, Loss of Component Cooling 0

PL-TBAE LP: EOP 7.0 - Loss of All Feedwater 11

PL-TBAE SEG-01: EOP 7.0 - Loss of All Feedwater 5

PL-TBAF LP: Transients, Emergency Prevention and Mitigation 11

PL-TBAF SEG-01: Steam Generator Tube Rupture (250 gpm) With Loss

1

of Offsite Power and Loss of D-Bus

PL-TBAF SEG-01: Steam Generator Tube Rupture (500 gpm) Without

4

Malfunctions

PL-TBAG LP: EOP-4.0, PCS Leak / Loss of Coolant Accident 10

PL-TBAG SEG-01: Large Break LOCAs 7

WORK DOCUMENTS

Number Description or Title Date

00025598-01 EMB-1209, Remove & Reinstall Motor/Install Vibration 05/04/06

Sensors

00026147-02 EX-03; Replace Winding Temp Gauges (2) & Liquid 04/17/06

Temp/RTS

00026658-01 Region Repair Testing of XFORMER EX-03 04/26/06

00279846-01 EMB-1209, Repair Damaged Stator 12/04/06

00296256-01 Replace Vent Plugs On Motor Oilers 06/16/05

00325492-01 EMA-1210, P-54A Spray PP Motor Brg Reservoir Cracked 05/12/07

Replace

51624068-01 Foreign Material In P-54A CTMT Spray Pump Oil Reservoir 05/16/07

51624500-07 P-54A; EMA-1210; Oil Leak On Spray Pump Motor 08/28/08

51632503-01 EMA-1210; P-54A Motor, Bearing Leaks, Add Dye to Oil 08/29/07

51632947-01 P-54A Motor Bearings, Slow Oil Leak On OB and IB Bearings 09/26/08

N/A QO-19B -Hi press SAF injection pump & ESS check valve 04/11/08

operability Results

N/A QO-19B -Hi press SAF injection pump & ESS check valve 01/16/08

operability Results

N/A QO-42X-IST remote position indication check SDC valve 06/13/08

N/A QO-42X-IST remote position indication check SDC valve 12/11/07

WO 00026902 YS-1400, remove, clean & inspect 09/26/07

WO 00138240 QO-14A - P-7A, IST service water pump 01/03/08

01

WO 00289427 QO-42X-IST remote position indication check SDC valve 12/15/06

WO 00292690- QO-19B -Hi press SAF injection pump & ESS check valve 01/16/07

01 operability

13 Attachment

WORK DOCUMENTS

Number Description or Title Date

WO 00297229 QO-14A - P-7A, IST service water pump 03/23/07

01

WO 00299713 QO-1 -Safety injection actuation system test 01/22/07

WO 00299727- QO-19B -Hi press SAF injection pump & ESS check valve 04/11/07

01 operability

WO 00302130 QO-1 -Safety injection actuation system test 04/24/07

WO 00304728 QO-5 -valve test procedure 06/07/07

WO 00306322 QO-42X-IST remote position indication check SDC valve 06/14/07

WO 00309551 QO-14A - P-7A, IST service water pump 12/20/06

01

WO 00311197 QO-43 - SIRWT outlet check vlv and SDC bypass & SDC 02/29/07

bypass vlv

WO 00311622 QO-1 -Safety injection actuation system test 08/06/07

WO 00315080 QO-5 -valve test procedure 08/29/07

WO 00317045 QO-14A - P-7A, IST service water pump 08/29/07

01

WO 00319941 QO-43 - SIRWT outlet check vlv and SDC bypass & SDC 03/04/07

bypass vlv

WO 00325408 QO-14A - P-7A, IST service water pump 05/14/07

01

WO 00325726 QO-14A - P-7A, IST service water pump 11/28/07

01

WO 00329761 QO-14A - P-7A, IST service water pump 11/29/07

01

WO 51623078 QO-5 -valve test procedure 05/29/08

WO 51623131 QO-5 -valve test procedure 02/25/08

WO 51623132 QO-14A - P-7A, IST service water pump 04/22/08

01

WO 51623274 MO-7A-1 - EDG 1-1 (K-6) 05/05/08

WO 51623277 QO-42X-IST remote position indication check SDC valve 03/13/08

WO 51623934 MC-17 Fuel oil sampling results 04/03/08

WO 51623977 MO-7A-1 - EDG 1-1 (K-6) 02/04/08

WO 51624094 QO-5 -valve test procedure 12/03/07

WO 51624356 MO-7A-1 - EDG 1-2 (K-6) 02/21/08

WO 51624637 MO-7A-1 - EDG 1-2 (K-6) 05/19/08

WO 51625037 MC-17 Fuel oil sampling results 06/02/08

WO 51625049 QO-14A - P-7A, IST service water pump 05/30/08

01

WO 51636608 QO-1 -Safety injection actuation system test 01/18/08

WO 51636618 QO-1 -Safety injection actuation system test 04/09/08

WO 51647606 QO-42X-IST remote position indication check SDC valve 09/10/08

WO 51654168 QO-1 -Safety injection actuation system test 06/27/08

WO 51662871 QO-14A - P-7A, IST service water pump 08/28/08

01

WO 51662993 QO-5 -valve test procedure 08/27/08

14 Attachment

WORK DOCUMENTS

Number Description or Title Date

WO 51667616 QO-1 -Safety injection actuation system test 10/07/08

WO 51669364 MO-7A-1 - EDG 1-1 (K-6) 08/04/08

WO 51671765 MO-7A-1 - EDG 1-2 (K-6) 08/18/08

WO 51689774 MC-17 Fuel oil sampling results 11/03/08

15 Attachment

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

ADV Atmospheric Dump Valve

AFW Auxiliary Feedwater

AOV Air-Operated Valve

ASME American Society of Mechanical Engineers

CDBI Component Design Basis Inspection

CFR Code of Federal Regulations

DC Direct Current

DRS Division of Reactor Safety

DRP Division of Reactor Projects

EDG Emergency Diesel Generator

EOP Emergency Operating Procedure

ESDE Excess Steam Demand Event

ESS Engineered Safeguards System

GL Generic Letter

IEEE Institute of Electrical & Electronic Engineers

IMC Inspection Manual Chapter

IN Information Notice

IST Inservice Test

kV Kilovolt

kW Kilowatt

LOCA Loss of Coolant Accident

LOOP Loss of Off-site Power

LP Lesson Plan

MOV Motor-Operated Valve

NCV Non-Cited Violation

NPSH Net Positive Suction Head

NRC U.S. Nuclear Regulatory Commission

ONP Off Normal Procedure

OTC Once Through Cooling

PARS Public Available Records System

PCS Primary Coolant System

PRA Probabilistic Risk Assessment

RAS Recirculation Activation System

RIS Regulatory Issue Summary

SDC Shutdown Cooling

SDP Significance Determination Process

SEG Simulator Exercise Guide

SG Steam Generator

SGTR Steam Generator Tube Rupture

SOP System Operating Procedure

SPAR Standardized Plant Analysis Risk

TIA Task Interface Agreement

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

UPS Uninterruptible Power Supply

VAC Volts Alternating Current

VDC Volts Direct Current

16 Attachment