ML18043A311
| ML18043A311 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/16/1978 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 7812060361 | |
| Download: ML18043A311 (3) | |
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General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 November 16, 1978 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 601-37 DOCKET 50-255 -
LICENSE DPR PALISADES PLANT -
IE INSPECTION 78-23 Consumers Power Company's responses to the two apparent items of noncompliance discovered during IE Inspection 78-23 are as follows:
Item Technical Specifi*cation 6. 8.1 requires that procedur.es covering sur:v:eillance and testing activities. of -safety-related equipment shall be impJ:emented.
Sur-veillance Procedure M0-19 requires corrective action in the event test __ data indicates containment spray pumps to be inoperable.
Contrary to the above, results of containment spray pump surveillance tests conducted on May 21, 1978, indicated the pumps to be inoperable and the action required by Procedure M0-19 was not taken.
Resuonse Discussion -
The acceptance criteria used to determine contaiTu~ent spray punp operability are based on pump flow measurements.
The instrument used to mea-sure the pump flow is common to all three pumps.
On May 8, 1978, during a test of the high-pressure safety injection (HPSI) pumps, it was noted that this flow indicator (FI 0404) was not indicating properly.
Because the HPSI pump accep-tance criteria is not a function of flow as measured by FI 0404, a Maintenance Order having a routine priority was issued to repair the flow indication.
The condition of this flow indicator was documented both in the Shift Supervisor's logbook on May 9 and in a Maintenance Order dated May 8, 1978.
On May 21, 1978 the test of the containment spray pumps was conducted, however, FI 0404 had not yet been repaired.
Because the status of FI 0404 was not known or remembered by the shift personnel conducting the test, the test was conducted and the faulty instrurnent was used to record the flow data.
The flows measured during the test indicated that all three spray pumps had failed to meet the test accep-tance criteria.
At this point, the following actions were taken:
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, 2
- l.
- 2.
A Deviation Report (D-PAL-78-197, dated 5~21-78) was written.
The prelimi-nary evaluation on *5-21-78 concluded that the. test failure was caused by FI o4o4.
The Shift Supervisor, in a memorandum dated 5-21-78 to the Operations Super-intendent, reported the test failure and concluded the test failure was caused by the flow indication.
- 3.
The Maintenance Order* to repair the flow indica~ion was upgraded in priority and th flow transmitter was repaired on 5-24-78.
Based on Items (1) and (2) above, the containment spray pumps were not declared inoperable and continued plant operation was considered justifiable.
Corrective Action Taken and Results Achieved The flow transmitter was examined and found to have a broken.zero spring.
The transmitter was repaired and recalibrated.
Subsequent testing was satisfactory.
Corrective Action To Be Taken To Prevent Recurrence Had shift personnel known that FI04o4 could not:have been relied upon for flow measurement*, the -instrument would *havec been repaired prior to conducting the test.-
Tagging _J>rocedures have been revised to include this type of deficiency.
Date When-FUll :.Compliance Will Be Achieved Based on the above corrective action, full compliance is considered to have been achieved.
Item 10 CFR 50.55a(g) and Procedure EM-0904 require inservice testing of ASME Code Class 1, 2 and 3 pumps to be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code 1974 Edition and Addenda through Summer 1975.
Contrary to the above:
- a.
The April 26, 1978 test results of the containment spray pumps* were in the "alert range" of Table IWP-3100-2 of ASME Code Section XI and testing was not increased as required-by Subarticle IWP-3230 until the causes of the deviations were determined and corrected.
- b.
The review of the May 21, 1978 test data for the containment spray pumps was not completed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of the test as required by ASME Code Section XI, Subarticle IWP-3230.
Response -
(Item a)
Discussion - The required test frequency under the conditions described above is once every two weeks.
After the April 26 test. the next test would have been due on May 10; however, because the plant was off line between May 1 and I
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. 3 May 12, the test due date was extended to one week after unit synchronization,'
This extension is permitted by the ASME Code:*
The test was conducted on 5-21-78.
After the test failure on 5-21-78, another test was issued on 5-23-78 to be per-formed after repair and recalibration of FO 0404.
This post repair.test was not performed until 6-15-78.
Failure to perform the post repair test is attributed to an administrative oversight.
Inasmuch as this was an isolated instance of failure to comply with the ASME testing requirements, no further corrective ac-tion is considered necessary.
Response -
(It~m b)
Discussion -
Two preliminary reviews were conducted on 5-21-78.
Thes~ reviews were documented in a memorandum from the Shift Supervisor to the Operations Super-intendent and in a Deviation Report (D-PAL-78-197).
These reviews concluded that*
the cause of the test failure was attributable to faulty flow indication.
A detailed review was performed on 5-26-78 after repair of the flow transmitter (FT 040).
This detailed review (analysis) should have been performed not later than 5-25-78.
As in Item a above, this is an administrative oversight which represents an isolated instance of not performing the Code-required analysis within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
Because these review/analysis requirements are. addressed in plant administrative procedures, no further corrective action is considered neces-sary.
David P Hoffman
- Assistant Nuclear Licensing Administrator CC:
Director; Office of Nuclear-Reactor Regulation Director, Office of Inspection and Enforcement 1