ML18052A941
| ML18052A941 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/20/1987 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8704270005 | |
| Download: ML18052A941 (8) | |
Text
General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 April 20,- 1987
- Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
IE INSPECTION REPORT 86032, ADDITIONAL INFORMATION IE Inspection Report 86-032 dated February 17, 1987 transmitted several unresolved and open items to which a written response was not required
- Subsequent to receiving the inspection report on February 20, 1987, several conversations have taken place between Consumers Power Company and the NRC regarding the status of these items. It should be noted that all issues regarding equipment-ope.rability and reliability have been addressed and that all remaining actions are considered enhancements to EEQ file auditability.
Attached are the statuses of the items identified in the inspection report and subsequently discussed with Mr ASGautam of the Region III staff, Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, NRG NRG Resident Inspector - Palisades OC0487-0039-NL02
POTENTIALLY ENFORECABLE/UNRESOLVED ITEMS Item No 86032-01 86032"'."05 Description Unqualified grease found in Limitorque actuators.
ASCO solenoid valves found installed without seals to prevent moisture intusion.
86032-06 Certain_ EEQ._files found not auditable due to incorrect acceptance criteria and and missing information.
86032-07 Rockbestos Firewall III EEQ files did not establish qualification of appropriate cables.
86032-09 Effects on low IR's during LOCA testing not addressed in General Electric Cable EEQ files.
86032-10 Plant installed Viking potted connectors found unqualified for instrumen-.
tation circuits.
IC0487-0059B-NL02 Status.
The _SUN 50 EP grease has been removed, actuators cleaned and
- qualified Exxon NEBULA EP-0 grease installed in EEQ listed Limitorque Valve Actuators.
Conduit seals have been installed for:
- 1) all EEQ listed ASCO solenoid valves in containment which
. need to energize after initiation of a design basis *accident (DBA), and
- 2) all EEQ listed ASCO solenoid valves outside of containment which were in a 100%
humidity accident environment and which need to energize after initiation of a DBA.
The above actions were taken as a result of a conference cail between CPCo and ASGautam on. January 12, 1987.
-The new accident profiles will be completed and incorporated by July 1, 1987, per conversation between KAToner, CPCo, and ASGautam on April 3, 1987.
Analyses necessary to close this item were completed April 6, 1987.
Analyses necessary to close* this
. item have been completed.
Per conversa_tion between KAToner, CPCo, and ASGautam on April 3, 1987, the analyses will be incorporated into EEQ files by July 1, 1987.
Analyses necessary to close this item have been completed.
Per-conversation between KAToner, CPCo, and ASGautam on April 3, 1987, the analyses wili be incorporated into EEQ files by July 1, 1987.
86032-11 Rosemount transmitter EEQ files did not justify demonstrated accuracy of these instruments for plant accident conditions.
86032-12 Limitorque actuators determined to be unqualified due to blocked T-drains
- IC0487-0059B-NL02 2
As presented to the NRC at Region III headquarters on March 16, 1987, analyses are complete.
Also completed are administrative controls necessary to assure required safety functions are achieved from equipment associated with Rosemount transmitters.
Actions taken are described in CPCo internal correspondence; KAT87*008 and RJF87*011, which are attached.
Primary coolant system pressure transmitters PT-0104A and B and PT~0105A and B are being evaluated for replacement.with new transmitters to significantly eliminate instrument inaccuracy.
Motor T-drains have been installed.
Reference LER 87-003 for actions taken.
OPEN ITEMS 86032-08 General Electric Cable 1 and 2 EEQ files had discrepancies in the qualification requirements for radiation.
86032-04 Lack of controlled procedure for replacement of "O" rings and torquing of transmitters.
86032-02 Deficiencies in the PPACS listing of maintenance activities for containment air coolers, position limit switches and motor oil in EEQ pumps.
86032-03 Lack of instructions for replacement of CELMARK connector "O_" -rings.
IC0487-0059B-NL02 3
Per conversation with KAToner, CPCo, and ASGautam on April 3, 1987, necessary actions to close this item will be complete by July 1, 1987.
This item has been completed by adding necessary administrative controls to instrument calibration sheets associated with Technical Specifications Surveillance Procedures.
Actions necessary to complete these items are underway and expected to be completed by May 15, 1987.
Actions considered necessary to resolve this concern are under evaluation.
Details of these specific actions will be provided to the NRC by May 15, 1987.
To RJFrigo, Palisades
,{~
From KAToner, Palisades CONSUMERS POWER Date March 19, 1987 COMPANY Subject PALISADES PLANT - EEQ TRANSMITTER ERROR Internal ANALYSIS - IMPACT ON OPERATING PROCED~S Correspondence cc RAFenech, Palisades KAT87*008
.KEOsborne, Palisades Engineering Analysis EA-KAT-87-01 was performed to assess the impact on the ability to achieve safety functions during LOCA and MSLB conditions in light of transmitter errors resulting from harsh environmental conditions.
As concluded in the analysis, required safety functions can be achieved even in the presence of such errors if the following recommended procedural revisions are incorporated:
REGARDING ENTRY INTO SHUTDOWN COOLING Recommendations:
- 1. Either the strict use of PI-0104 (preferably narrow range, however either narrow or wide range is acceptable) and PTR-0125, or the average of all qualified PCS pressure indications (the aforementioned indicators as~ll as indicators PI-0105A through D) are to be used.to determine when the Shutdown Cooling System (SDCS) isolation valves M0-3015 and M0-3016 are to be manually opened to commence SDC.
- 2.
The indica.tion-_at-which the shes-i-solation valves are to be openea should be revisedfrom 270 psia to 180 psia to ensure that the upper and lower pressure limits as described in Item 1 above are not exceeded.
Note:
The strict use of PI-0104 and PTR-0125 is preferred over averaging all indica-tions in this case, since the shifts in output owing to transmitter error are less for these instruments than that expected for the 0105 loops previously identified.
Incorporating Recommendation 2 will ensure that neither the maximum SDCS design pressure or the minimum PCS pressure to ensure subcooling will be exceeded if PI-0104 and PTR-0125 are used (see attached sketch).
The 0105 loop errors result in peak-to-peak output shift variations ~f a magnitude which exceeds the pressure band between the overpressurization and subcooling limits regardless of what pressure within the band would be speci-fied as signifying when the operator should open the valves.
As a result, using the 0105 loops for this function would require averaging all readings; a practice which would likely reduce the overall inaccuracy of the reading but would not necessarily ensure that the actual PCS pre$sure would be within the acceptable bounds (see attached sketch).
IC0387-1473A-TC01
REGARDING ENTRY INTO "ONCE-THROUGH" COOLING Recommendations:
- 1.
A specific caution stateme~t should be added to em~~gency procedures to
. indicate that all four wide range steam generator loop indications (LI-0757A and B for Steam Generator A and.LI-0758A and B for Steam Gen-erator B) should be scanned with an average value obtained to ascertain when to enter PCS "once-through" cooling.
- 2.
Core exit thermocouples should also be monitored as a backup check to the wide range level indication.
Proceeding to "once-through" cooling should be based on both:
- Steam* generator low level which indicates that the generator may not be capable of serving as an effective heat sink, and 2
- Core exit thermocouples which confirm steam generator ineffectiveness by showing inadequate PCS cooldown.
Notes:
A.
In this case, the -84% indication signifying when "once-through" cooling is to be initiated is considered acceptable.
(At this level, 36% of the tubes are submerged; a level at which effective heat transfer can still be achieved.)
Although maximum potential transmitter error could result in an actual level of -120% when -84% is indi:Cated, appreciable invent_ory
- (- 23%) will -st-ill exist in the steam generator, -a_nd tfie-likelihood of steaming the steam generator shell dry before corrective actions are taken is almost non-existent.
S.ince safety function status checks are performed periodically, it is expected that the operator will be aware of either low or descending steam generator level in a timely manner.
B.
Based on discussions conducted subsequent to completion of the analysis, it is requested that the Operations Department review emergency procedures to determine if existing guidance related to the assessment of "once-t;hrough" cooling entry conditions fulfills the intent of the above recouunendations.
If the existing guidance is considered effective, no procedural revision should be undertaken since unnecessary revision may render the procedures confusing.
IC0387-1473A-TC01
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- 1 To KAToner From RJFrigo ~
CONSUMERS POWER Date March 26, 1987 COMPANY Subject PALISADES PLANT-Internal EEQ TRANSMITTER ERRORS Correspondence cc RAFenech RJF87*0ll KEOsborne Per memo KAT87*008 the following change has been made to the EOPs in response to transmitter errors resulting from degraded containment conditions:
a)
EOPs 4.0 (LOCA), 6.0 (ESDE), & 9.0 (Functional Recovery) have been modified to state "PCS pressure 270 psia (180 psia for degraded containment) OR less as indicated on PI-0104 OR PTR-0125" as a condition to go on shutdown cooling.
b)
No changes are warranted for the four S/G wide range instruments.
The use of these instruments is in conjunction with other indications (Qualified CETs & PCS pressure trends) to determine if S/G heat removal capability is lost.
IC0387-0003A-OP01