ML090150569
| ML090150569 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| 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
DISTRIBUTION:
RidsNrrPMPalisades
RidsNrrDorlLpl3-1
RidsNrrDirsIrib Resource
Mark Satorius
Kenneth Obrien
Cynthia Pederson
DRPIII
DRSIII
Patricia Buckley
ROPreports@nrc.go
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No:
50-255
License No:
Report No:
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
1
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.
Enclosure
2
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.
Enclosure
3
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.
Enclosure
4
.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:
Emergency Diesel Generator (EDG) (1-2) Load Capability: The inspectors
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.
Enclosure
5
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.
Enclosure
6
Turbine Driven Auxiliary Feedwater Pump (P-8B): The inspectors reviewed the
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.
Containment Spray Pump (P-54A): The inspectors reviewed the containment
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.
Enclosure
7
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.
Enclosure
8
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.
Shutdown Cooling (SDC) Heat Exchanger Bypass Valve (CV-3006): The
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.
Enclosure
9
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
Enclosure
10
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
Enclosure
11
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
Enclosure
12
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
Enclosure
13
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;
IN 2006-22, New Ultra-Low Sulfur Diesel Fuel Oil Could Adversely Impact Diesel
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.
Enclosure
14
.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;
EC 8350, Replace Containment Spray Isolation Valves; and
DCR 10519, Make Temporary Modification EC 8920 Permanent.
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 Steam Generator Tube Rupture;
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.
Enclosure
15
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
Attachment
1
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
Attachment
2
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened 05000255/2008009-01
Inadequate Analysis of Emergency Diesel
Generator 1-2 Loading During Design Basis Events
(1R21.3.b.(1))05000255/2008009-02
Failure to Establish Correct Technical Specification
Limits (1R21.3.b.(2))05000255/2008009-03
Non-Safety-Related Components Credited in Steam
Generator Tube Rupture Accident Analysis
(1R21.3.b.(3))
Closed 05000255/2008009-01
Inadequate Analysis of Emergency Diesel
Generator 1-2 Loading During Design Basis Events
(1R21.3.b.(1))05000255/2008009-02
Failure to Establish Correct Technical Specification
Limits (1R21.3.b.(2))
Discussed
None
Attachment
3
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,
Sh. 11-12/8A
Containment Cooler Recirculation Fan V1A
3
52-1209,
Sh. 11-12/7A
Containment Cooler Recirculation Fan V2A
3
52-1210,
Sh. 11-12/7B
Containment Cooler Recirculation Fan V3A
3
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
Palisades AOV(s) CV-0937 and CV-0938 Using The
EPRI MOV Butterfly Valve Performance Prediction
Methodology
2
EA-AFW-CA016278
Analysis of Auxiliary Feedwater System Parameters
when Cross-Connected to the Fire Protection System
using Pipe-Flo
1
EA-AOV-09
Engineering Analysis for Operability of CV-3029, CV-
3030, CV-3031, and CV-3057
0
EA-AOV-10
Palisades High Pressure Air Solenoid Valve Testing
0
Attachment
4
CALCULATIONS
Number
Description or Title
Revision
EA-AOVCAP-GATE-
ESS-01
Actuator Capability Review for Air Operated Gate
Valves in the Engineered Safeguards System (ESS)
1
EA-AOVCAP-MSS-01
Actuator Capability Review for Air Operated Valves
with Reverse Acting Fail Closed Diaphragm
1
EA-AOVSYS-ESS-1
System Level Design Basis Review for Air Operated
Valves (AOV) in the Engineered Safeguards System
(ESS)
7
EA-AOVT/T-Double-01
Thrust requirements for Palisades double seat globe
valves
1
EA-AOVT/T-ESS-3
Evaluation of Stem Thrust Requirements for AOVs
CV-3029 & CV-3030
0
EA-AOV-WKLINK-06
Weak Link Calculation for AOVs CV-3029 and CV-
3030 from
Crane Valves
1
EA-A-PAL-86-148-01
Heating Ventilation Air Conditioning (HVAC)
Appendix R Damage to Alternate Shutdown
Equipment
2
EA-A-PAL-94-095
Auxiliary Feedwater Pumps Net Positive Suction
Head
0
EA-A-PAL-94-279-009
Seismic Analysis and Weak Link Calculation for 12
Bolted Bonnet Gate Valve
0
EA-APR-96-004
Appendix R Periodic Review to Asses Drawing
Impacts on Safe Shutdown Circuit Analysis
0
EA-BWH-97-001
Evaluation of P-8A/B/C Full Flow Data and
Establishment of P-8A/B Inservice Testing Reference
Values/Acceptance Limits
0
EA-C-PAL-95-0053B-01
Incorporation of a Higher Auxiliary Feedwater Pump
Low Suction Pressure Trip Setpoint into the T-2/T-81
Inventory Calculations Using the RETRAN Program
2
EA-C-PAL-95-0877D
Evaluation of potential of excessive air entrainment
caused by vortexing in the SIRWT during a LOCA.
0
EA-C-PAL-96-0837A-01
Analysis of fuel volume of the EDG belly tank at the
sump start fill level switch setpoint
0
EA-C-PAL-96-0883-01
Containment Spray Pump Runout and Impact of Low
Flow Rates on Pump
0
EA-C-PAL-97-1650A-01
Revised Hydraulic Inputs for Emergency Diesel
Generator Steady State Load Calculation
2
EA-C-PAL-99-1209B-01
Generation of flow rate acceptance criteria for TS
surveillance test RO-216
1
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
Flooded Condition
0
EA-D-PAL-93-110
Containment Air Cooler Air Flow Evaluation at
Flooded Condition
0
Attachment
5
CALCULATIONS
Number
Description or Title
Revision
EA-D-PAL-93-272A-00-
16-01
Allowed Degradation for Containment Spray Pumps
in ASME XI Pump Testing
0
EA-EAR-2001-0333-01
Generation of ESS pump performance curves for use
with the Pipe-Flo ESS Hydraulic Model
3
EA-EAR-96-0204-01
Documentation of T-25A and T-25B level transmitter
calibration values and worst case low level alarm
setpoint
3
EA-EC10838-01
Allowable Time for Operating HPSI Pump with no
CCW Cooling
0
EA-EC-235-01
Assessment of the High Pressure Air Systems
Capability to Cycle Valves in the West Engineering
Safeguards
0
EA-EC6432-01
Palisades EDG Diesel Fuel Oil Storage
Requirements
0
EA-ELEC-AMP-025
Battery Charger ED-15, 16, 17, 18 Output Current
Required to Recharge Batteries ED01 and Ed-02
1
EA-ELEC-FLT-005
Short Circuit for the Palisades Class 1E Station
Batteries D01 and D02
1
EA-ELEC-LDTAB-005
Emergency Diesel Generators 1-1 & 1-2 Steady
State Loading
8
EA-ELEC-LDTAB-009
Battery Sizing for The Palisades Class 1E Station
Batteries D01 and D02
3
EA-ELEC-VOLT-026
Voltage Drop Model for the Palisades Class 1E
Station Batteries D01 and D02
1
EA-ELEC-VOLT-037
Palisades Degraded Voltage Calculation For The
Safety-Related MOVs
3
EA-ELEC-VOLT-052
DC Control Circuit Minimum Required Voltage
Analysis
0
EA-FC-842-01
Input/Output EA for FC-842 AFW Pumps P-8A, P-8B,
and P-8C Control System Upgrade
0
EA-FC-951-01
Containment Cooling Load Evaluation for
Replacement Cooling Coil
0
EA-FC-951-03
Code Reconciliation for Replacement Containment
Air Coolers, Piping, Pipe Supports, and Coil Supports
0
EA-FC-951-04
New Containment Air Cooler Inlet/Outlet Pipe Size
Verification
2
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
Replacement Air Coolers (Aerofin Coils)
0
EA-FC-951-09
Replacement Air Cooler Performance
0
EA-FC-954-02
Low Pressure Suction Trip on the Auxiliary
Feedpump - Setpoint Change
3
Attachment
6
CALCULATIONS
Number
Description or Title
Revision
EA-FC-958-03
EDG diesel fuel oil transfer system requalification -
electrical instrumentation
1
EA-FC-958-04
Calculation to size and provide instrumentation levels
for the replacement of the diesel fuel oil tank T-10
with T-10A
2
EA-FC-966-01
Mechanical Design Basis Analysis for AFW Steam
Supply (CV-0522A & B) - Modification FC-966
3
EA-GEJ-96-06
Minimum Aux. Feed Requirement for All Aux. Feed
Pumps
0
EA-GL-96-06-SWS-01
Calculation of GL 96-06 Water Hammer Loads in
Containment Air Cooler Service Water Piping Using
Pipe-Flo
0
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
with CSS Throttling
1
EA-MOV-KALSI-001
Kalsi Engineering Thrust Rating Increase of the Limit
torque Actuators
0
EA-MOV-SIG-0499
Safety Significance Determination of Active MOVs in
the IPE Model and Results
0
EA-PIPEFLO-CSS-01
Containment Spray System Model Using Pipe-Flo
0
EA-PIPEFLO-ESS-01
Integrated Pipe-Flo Hydraulic Model of the
Containment Spray, High and Low Pressure Safety
Injection Systems
2
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
SDC Return Valves MO-3015 and MO-3016
0
EA-RSW-94-002
Containment Spray Pump Differential Pressure
Indication Uncertainty
1
EA-SC-87-156-01
Increase the Operator Air Pressure for Auxiliary
Feedwater Pump Flow Control Valves and Change
the Time Delay for AFW Pump Start
1
EA-SC-87-156-02
Examination of Effects of Delay in Achieving Full
AFW System Flow
0
EA-SC-88-185-02
Evaluation of Change in SIRWT and Containment
Sump Valve Stroke Overlap
0
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
RETRAN Model Verification
0
EA-SDW-95-001
Generation of minimum and maximum HPSI/LPSI
system performance curves using Pipe-Flo
2
Attachment
7
CALCULATIONS
Number
Description or Title
Revision
EA-SDW-95-003
Maximum Containment Spray Flow Rates Using
Pipe-Flo
0
EA-SWS-M-6-1
Acceptance Criteria for Leak Testing the
Containment Coolers
0
EA-T-223-1998-01
Evaluation of Special Test T-223 and CCW System
Analysis Under Varied Operating Conditions Using
Pipe-Flo
0
JCW-94-017
SI tank discharge line operability due to water
hammer concern
10/10/94
Piping stress analysis
02/25/93
SUT1-1/CO4/450-
451S1
SUT 1-1 345KV Phase Overcurrent Relays
12/17/84
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
Quality Programs with SBO Compliance
---
Apparent Cause Report. Quality Classification of SBO
Components
04/17/06
CR-PLP-2003-
00572
Documentation Inconsistencies for the Atmosphere Steam
Dump
01/28/03
CR-PLP-2006-
01184
Quality Programs with SBO Components
03/16/06
CR-PLP-2007-
01637
Uncompleted recommendation from old CR to prevent
waterhammer in the SI lines
04/19/07
CR-PLP-2007-
04122
CV-3025 conduit support clamp has fallen off support bracket
09/18/07
CR-PLP-2007-
04259
Issues related to EDG fuel oil tank volume calculations
09/21/07
CR-PLP-2008-
02646
Overly restrictive stroke time requirements associated with
operability of CV-3025 & Cv-3055
06/13/08
CR-PLP-2008-
04318
Bolt Broken Off On Space Heater Cover On The Generator for
the 1-2 Emergency Diesel Generator
10/20/08
CR-PLP-2008-
04542
West safeguards door 59 was difficult to latch
11/05/08
CR-PLP-2008-
04546
Potential loss of diesel fuel oil transfer pumps due to spray
from circulating water pipe
11/06/08
CR-PLP-2008-
04550
NRC Identified 2 Fire Brigade Lockers with Missing Seals
11/06/08
CR-PLP-2008-
04572
Rusty Spring in Support HB23-H282 (Service Water Supply
Header between Control Valves CV-0846 and CV-0857)
11/07/08
Attachment
8
CORRECTIVE ACTION PROGRAM DOCUMENTS
Number
Description or Title
Date
CR-PLP-2008-
04573
Potential Impact of Emergency Diesel Generator
Intake/Exhaust Room Temperature
11/07/08
CR-PLP-2008-
04573
Evaluate Impact of EDG Intake/Exhaust Room Temperature
11/07/08
CR-PLP-2008-
04580
D/G load calc did not account for worst case load from CAC
fan motors (Reportable to NRC 8-hr and LER)
11/07/08
CR-PLP-2008-
04690
Discrepancy Between Calculation EA-ELEC-LDTAB-009 and
EOP Supplement 8
11/18/08
CR-PLP-2008-
04707
EDG allowable water level in T-10A potentially not
conservative.
11/19/08
CR-PLP-2008-
04708
Emergency Diesel Generator Fuel Consumption Rate
11/19/08
CR-PLP-2008-
04708
Non-conservative EDG fuel consumption rate used in diesel
fuel oil storage calculation.
11/19/08
CR-PLP-2008-
04739
As-found service water flow did not meet acceptance criteria
was not captured in the corrective action program
11/20/08
CR-PLP-2008-
04747
Security Procedures did not Contain Guidance to Obtain
Control Room Permission Before Manually Turning on
Security Lighting when Bus 1D is being Powered Solely from
EDG 1-2
11/21/08
CR-PLP-2008-
04853
Minor calculation error in EA-C-PAL-94-0130-01
12/01/08
CR-PLP-2008-
04913
Calculation Deficiencies Associated with Station Battery
Chargers
12/04/08
CR-PLP-2008-
04972
Discrepancy Between Calculation EA-ELEC-FLT-005,
Revision 1 and FSAR Table 8-5
12/09/08
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
Control Center Warehouse
79
E-1, Sh. 1
Single Line Meter & Relay Diagram 480 Volt Motor Control
Center Warehouse
79
E-1, Sh. A
Single Line Meter and Relay Diagram
9
E-132 Sheet 1
Schematic Diagram - Start-up Transformer 1-1 & 1-2
Incoming Breakers
25
E-17 Sheet 17
Logic Diagram - Generator Breaker and M.O.D Control
3
E-242, Sh. 3
Schematic Diagram Vol. Control Shutdown Cooling &
Press. Relief Motor Oper. Valves
23
E-8 sheet 2
Single Line Meter & Relay Diagram - 125 VDC
51
VEN-M-101
Stress Isometric - Auxiliary Feedwater Pump Suction
6
Attachment
9
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-
191 Resolution
0
07-0007
Replace Containment Spray Isolation Valves per GSI-
191 Resolution
1
QF-0501(FP-E-SE-
03)
Atmospheric Dump Valves (ADVs)
02/24/05
Screening 07-0078
Disable Fast Transfer
0
SDR-99-0658
Evaluation of Special Test T-223 and CCW System
Analysis Under Varied Operating Conditions Using
Pipe-Flo
0
MISCELLANEOUS
Number
Description or Title
Date or
Revision
5935-M-12
Specification For The Emergency Diesel Generators
Palisades Plant Consumers Power Company
12/12/68
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
Systems
5
DBD-5.03
Design Basis Document Emergency Diesel Generator
Performance Criteria
7
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
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,
Your Inquiry 5935M12, Our Proposal SF246/SMW1201,
Emergency Diesel Generators Consumers Power Co.
11/26/68
Attachment
10
MISCELLANEOUS
Number
Description or Title
Date or
Revision
N/A
NMC Letter to Fairbanks & Morse Alco Engines, Mr. Ted
Stevenson from Mr. Greg Brock, Palisades Nuclear Plant
02/15/07
N/A
TS change request - electrical power systems, additional
information
06/27/97
N/A
Potential for steam-water waterhammer in the Palisades
Injection Piping
12/03/08
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
Turbine-Driven Auxiliary Feedwater Pump P-8B
3/14/00
NRC Letter
Notice of Enforcement Discretion - Re: Backup Steam
Supply for Turbine-Driven Auxiliary Feedwater Pump P-8B
2/18/00
SL-5578
Evaluation of Containment Cooler Control Valve Bypass
Flow
0
UFSAR Chapter
14.15
Steam Generator Tube Rupture With a Loss of Offsite
Power
23
MODIFICATIONS
Number
Description or Title
Date or
Revision
Make Temporary Mod EC8290 (Install Supplemental 2400V
DG and Circuit Breaker 152-403) Permanent
0
EDG run time from day tank
12/02/08
Addition of Supplemental Diesel Generator (SDG) & Breaker
152-403 at Safeguards Bus A14, Cubicle 4
0
Replace Containment Spray Isolation Valves per GSI-191
Resolution
0
Evaluate Operation of the Site Diesel Fuel Burning Equipment
with Diesel Fuel with Sulfur Content Less than 15ppm (Ultra
Low Sulfur Diesel Fuel)
04/12/06
ASDV Back-up Nitrogen Supply
9/28/93
OPERABILITY EVALUATIONS
Number
Description or Title
Date or
Revision
CR-PAL-2008-
04708
Emergency Diesel Generator Fuel Consumption Rate
12/09/08
Attachment
11
OPERABILITY EVALUATIONS
Number
Description or Title
Date or
Revision
CR-PLP-2008-
04580
Emergency Diesel Generator Load Calculation Did Not
Account For Worst Case Load From The Containment Air
Cooler Fan Motors (V-1A, V-2A and V-3A)
1
CR-PLP-2008-
04580 CA 3
Past Operability Review for 1-2 EDG
12/22/08
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
Classification of Structures, Systems, and Components
2
Margin Management
3
Process Applicability Determination
7
Protective and Caution Tagging
10
3
EOP Supplement 12
7
EOP Supplement 13
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
Loss of Coolant Accident Recovery
18
Steam Generator Tube Rupture Recovery
14
Steam Generator Tube Rupture Recovery
14
Excess Steam Demand Event
16
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
Emergency
Diesel Generator 1-2
67
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
Attachment
12
PROCEDURES
Number
Description or Title
Revision
ONP-20
Off Normal Procedure Diesel Generator Manual
Control
23
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
Emergency
Diesel Generator 1-2 24-Hour Load Run
14
SOP-12
Feedwater System
54
SOP-19
Instrument Air System
46
SOP-20
High Pressure Control Air System
25
SOP-22
45
SOP-22
System Operating Procedure Emergency Diesel
Generators
45
SOP-3
Safety Injection And Shutdown Cooling System
75
SOP-4
Containment Spray System
24
SOP-5
Containment Air Cooling and Hydrogen Recombining
System
26
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
Diesel Generator 1-2 (WO 51671765-01)
08/18/08
MO-7A-2
Technical Specification Surveillance Procedure Emergency
Diesel Generator 1-2 (WO 51676751-01)
09/15/08
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
Diesel Generator 1-2 24-Hour Load Run (WO 00303648-01)
04/16/07
RO-128-2
Technical Specification Surveillance Procedure Emergency
Diesel Generator 1-2 24-Hour Load Run (WO 51658738-01)
10/21/08
Attachment
13
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
of Offsite Power and Loss of D-Bus
1
PL-TBAF
SEG-01: Steam Generator Tube Rupture (500 gpm) Without
Malfunctions
4
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
Sensors
05/04/06
00026147-02
EX-03; Replace Winding Temp Gauges (2) & Liquid
Temp/RTS
04/17/06
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
Replace
05/12/07
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
operability Results
04/11/08
N/A
QO-19B -Hi press SAF injection pump & ESS check valve
operability Results
01/16/08
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
YS-1400, remove, clean & inspect
09/26/07
01
QO-14A - P-7A, IST service water pump
01/03/08
QO-42X-IST remote position indication check SDC valve
12/15/06
01
QO-19B -Hi press SAF injection pump & ESS check valve
operability
01/16/07
Attachment
14
WORK DOCUMENTS
Number
Description or Title
Date
01
QO-14A - P-7A, IST service water pump
03/23/07
QO-1 -Safety injection actuation system test
01/22/07
01
QO-19B -Hi press SAF injection pump & ESS check valve
operability
04/11/07
QO-1 -Safety injection actuation system test
04/24/07
QO-5 -valve test procedure
06/07/07
QO-42X-IST remote position indication check SDC valve
06/14/07
01
QO-14A - P-7A, IST service water pump
12/20/06
QO-43 - SIRWT outlet check vlv and SDC bypass & SDC
bypass vlv
02/29/07
QO-1 -Safety injection actuation system test
08/06/07
QO-5 -valve test procedure
08/29/07
01
QO-14A - P-7A, IST service water pump
08/29/07
QO-43 - SIRWT outlet check vlv and SDC bypass & SDC
bypass vlv
03/04/07
01
QO-14A - P-7A, IST service water pump
05/14/07
01
QO-14A - P-7A, IST service water pump
11/28/07
01
QO-14A - P-7A, IST service water pump
11/29/07
QO-5 -valve test procedure
05/29/08
QO-5 -valve test procedure
02/25/08
01
QO-14A - P-7A, IST service water pump
04/22/08
MO-7A-1 - EDG 1-1 (K-6)
05/05/08
QO-42X-IST remote position indication check SDC valve
03/13/08
MC-17 Fuel oil sampling results
04/03/08
MO-7A-1 - EDG 1-1 (K-6)
02/04/08
QO-5 -valve test procedure
12/03/07
MO-7A-1 - EDG 1-2 (K-6)
02/21/08
MO-7A-1 - EDG 1-2 (K-6)
05/19/08
MC-17 Fuel oil sampling results
06/02/08
01
QO-14A - P-7A, IST service water pump
05/30/08
QO-1 -Safety injection actuation system test
01/18/08
QO-1 -Safety injection actuation system test
04/09/08
QO-42X-IST remote position indication check SDC valve
09/10/08
QO-1 -Safety injection actuation system test
06/27/08
01
QO-14A - P-7A, IST service water pump
08/28/08
QO-5 -valve test procedure
08/27/08
Attachment
15
WORK DOCUMENTS
Number
Description or Title
Date
QO-1 -Safety injection actuation system test
10/07/08
MO-7A-1 - EDG 1-1 (K-6)
08/04/08
MO-7A-1 - EDG 1-2 (K-6)
08/18/08
MC-17 Fuel oil sampling results
11/03/08
Attachment
16
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
ADV
Atmospheric Dump Valve
Air-Operated Valve
American Society of Mechanical Engineers
Component Design Basis Inspection
CFR
Code of Federal Regulations
Direct Current
Division of Reactor Safety
Division of Reactor Projects
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
Inservice Test
kV
Kilovolt
kW
Kilowatt
Loss of Coolant Accident
Loss of Off-site Power
Lesson Plan
Motor-Operated Valve
Non-Cited Violation
Net Positive Suction Head
NRC
U.S. Nuclear Regulatory Commission
ONP
Off Normal Procedure
OTC
Once Through Cooling
Public Available Records System
Primary Coolant System
Recirculation Activation System
Regulatory Issue Summary
Significance Determination Process
SEG
Simulator Exercise Guide
Steam Generator Tube Rupture
System Operating Procedure
Standardized Plant Analysis Risk
Task Interface Agreement
TS
Technical Specification
Updated Final Safety Analysis Report
Uninterruptible Power Supply
VAC
Volts Alternating Current
VDC
Volts Direct Current