ML18054A861

Documents Rationale for 890720 Request for Enforcement Discretion to Extend 24 H Action Statement in Order to Complete Surveillance Testing of Certain Containment Penetrations

ML18054A861
Person / Time
Site:	Palisades
Issue date:	07/21/1989
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8907260005
Download: ML18054A861 (6)

Text

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• -- ~* POWERINli MICHlliAN'S PROGRESS General Offices: 1945 West Parnell Road, Jackson; Ml 49201 * (517) 788-0550 July 21, 1989 US Nuclear Regulatory Conunission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

REQUEST FOR ENFORCEMENT DISCRETION NRC Staff was informed by telephone conference call on July 20, 1989 of our request for the Regional Administrator to exercise enforcement discretion to extend a twenty-four (24) hour action statement in order to complete surveil-lance testing of certain containment penetrations. In that conference call, verbal authorization was received. This letter is submitted to document our rationale for the request.

NRC internal memorandum EGM-85-05B, dated February 27, 1987 identifi~s alter-natives licensees may initiate to obtain relief from Technical Specification limiting conditions for operation that would unnecessarily require a plant shutdown. One of the alternatives is the exercising of enforcement discretion by the Regional Administrator. To use this alternative, the memorandum suggests several criteria that should be considered. These criteria include;

1) considerations to promote the safest course of action, 2) situations which have not been reasonably foreseen by the licensee, 3) timeliness of action is of essence to preclude imposition of a transient, and 4) operation in excess of the action statement for the granted period of relief would not place the Plant in an unsafe condition. The following discussion of circumstances and Plant safety considerations address these criteria and provides our rationale for this request.

Justification For Discretionary Enforcement Discussion of Circumstances:

At approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on July 19, 1989 Technical Specification Surveil-lance Test MI-5 was initiated to test pressure switches associated with the containment high pressure. initiation logic. During the conduct of the test at approximately 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, a leak was noticed on V-1805. The test was stopped 89072.:.0005 890721 PDR p . ADOCI< 05000:255 F'DC OC0789-0157-NL04

Nuciear Regulatory Commission Palisades Plant Request for Enforcement Discretion July 21, 1989

• 2 and System Engineering and Operations were notified. Subsequently, the Shift Supervisor identified this as a possible containment integrity issue and notified Plant management who were participating in the Annual Site Emergency Exercise. At 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br /> the Emergency Exercise was terminated.

At 1400 on July 19, 1989 the Plant Review Committee (PRC) convened to discuss the leakage of valve V-1805 on penetration 48. The leak locations were on the threaded sections of V-1805 which would be isolated from containment when the valve is closed. The Shift Supervisor noted that the valve is closed and locked. PRC concurred with that action. PRC noted that with the valve closed, the I&C Technician was able to pressurize the valve (the side away from containment) to about 70 psig of the 85 psig needed for the calibration of PT-1805, but he was unable to maintain the pressure with his hand pump.

Based on the successful calibrations last month, it is believed this leakage has only been present for a maximum of one month. PRC concluded that since the leakage of V-1805 has not been quantified, a leakage test on V-1805 should be expeditiously conducted to determine if the total containment leakage is less than 0.6 L and whether further immediate repairs are needed to a

re-establish containment integrity. PRC directed a test to be written to perform this test.

PRC also discussed whether V-1805 could be considered a containment isolation valve. Engineering provided verbal information that V-1805 is equivalent to the other valves which are containment isolation valves. PRC concluded that sufficient justification is present to classify V-1805 as a containment isolation valve. However, PRC directed that a safety evaluation, per 10CFR50.59, be conducted to determine if that reclassification constituted an unreviewed safety question.

The third matter PRC discussed was the actions needed to perform local leak rate testing on portions of the penetrations #48 and #17 which were found not to be tested previously by the Local Leak Rate Test (LLRT) or the Integrated Leak Rate Test (ILRT). PRC discussed that the monthly calibrations done on the pressure switches and transmitters on these sections of piping provided good evidence that these lines were intact and did not leak. During calibration, pressues ranging from 10 psig to 200 psia were imposed. However, the calibrations did not qualify as LLRT's. The failure to conduct the required surveillances was analogous to a previous occurrence where a Technical Specification test, (R0-32-47, another LLRT) was missed in May 1988, thereby putting the plant into Technical Specification 3.0.3. This occurrence was reported as Licensee Event Report 88-008, "Data Entry Error Results In Failure To Complete Required Containment Leak Rate Test". At that time the provisions of Generic Letter 87-09 were used to allow a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to conduct the required testing. The use of the provisions of Generic Letter 87-09 was discussed in NRC Inspection Report 88-014. The provisions of Generic Letter 87-09 have been submitted as a formal Technical Specification Change Request on April 3, 1989. Based on the evidence that these sections of piping were leak free from the prior calibrations, PRC considered it prudent not to declare the piping inoperable and to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the testing to be conducted to demonstrate that operability. PRC directed these penetration tests be developed and run within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

OC0789-0157-NL04

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\,' Palisades Plant

• Nuciear Regulatory Commission Request for Enforcement Discretion July 21, 1989

• 3 At 1545 immediately after the PRC meeting, the Technical Engineer and the Plant General Manager met with the NRC Resident Inspector and the Chief, Project Branch No. 2 to explain the situation and the direction being pursued by the Plant to expeditiously verify that containment integrity was being maintained. A conference call was established with Palisades Project Managers at NRR to explain the one hour report of July 17, 1989 on the main steam line break analysis and to discuss the containment integrity issue of July 19, 1989. During the conference call three major issues were discussed in the following order:

1. V-1805 was found to be leaking during a calibration of PT-1805. Our actions discussed were;

a. V-1805 was closed and locked,

b. the leakage is isolated from containment by closing the valve,

c. the testing of V-1805 would be done expeditiously,

d. V-1805 would be reclassified as a containment isolation valve.

2. In that only portions of the penetration around the pressure transmitters 1805 and 1812 had been tested during the ILRT and that the piping associated with the remaining pressure transmitters and pressure switches were not tested either in the LLRT or the ILRT further testing is required. The remaining portions of piping would be tested within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> given as the NRC staff's position in Generic Letter 87-09 and_as submitted as a Technical Specification Change Request on April 3, 1989. We noted that this Generic Letter guidance has been used previously by us.

3. The calibration of the pressure switches and pressure transmitters was being conducted by opening the two containment isolation valves and closing another.valve which was not classified as a containment is6lation valve. The calibration of the pressure switches and transmitters would be revised to eliminate that practice which is not allowed by Technical Specifications.

After leaving the PRC meeting at 1530, a representative of the Plant Nuclear Licensing Department reviewed documentation associated with Systematic Evaluation Program (SEP) Topic VI-4, "Containment Isolation System". This review, conducted with a Plant representative involved with the SEP issue in 1981, was completed at 1630. The review concluded that no discussion regarding compliance with 10CFR50 Appendix J was present, even though the penetration in its current configuration was identified. Further review identified that as a result of an NRC Notice of Violation issued in Inspection Report 80-02, these penetrations were modified to their current configuration. This modification installed the new valves currently classified as the "containment isolation valves".

As a-result of this review, the leakage associated with V-1805 and the fact that no information was readily available regarding compliance with 10CFR50 Appendix J for penetrations 17 and 48, the condition was deemed to be OC0789-0157-NL04

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\i Palisades Plant

• Nuclear Regulatory Commission Request for Enforcement Discretion July 21, 1989

• 4 reportable under 10CFR50.72(b)(2)(iii)(B) as a condition that could have prevented the fulfillment of a system needed to control the release of radio-active material. The report was initiated at 1715 and completed at approximately 1800.

At 0000 on July 20, 1989 a PRC meeting was convened to review the reclassifi-cation of V-1805 to a containment isolation valve and to review the procedure for testing V-1805 and the portions of penetration 48 and 17 which did not have LLRT's conducted on them. At 0215 PRC approved both issues and did not consider an unreviewed safety question existed.

At 1045 on July 20, 1989 the PRC met again to discuss the status of testing with respect to end of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period instituted under Generic Letter 87-09 on July 19, 1989. Based on the present status of testing, it was determined that an additional 12 to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> past the 1500 hour0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> deadline would be required. PRC also reviewed the data collected for the first three tests and concluded that continued testing past 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> presented the safest course of action without imposing a Plant transient (shutdown). At this time the PRC developed the below listed Plant Safety Considerations and decided to pursue enforcement discretion in accordance with NRC internal memorandum EGM-85-05B dated February 27, 1987. The Plant NRC Resident Inspector was then notified at approximately 1045 of our intent. At 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> on July 21, 1989 the Resident Inspector and other NRC Staff presently onsite were presented with the following Plant_Safety Considerations.

Plant Safety Considerations:

Procedures have been written and approved as indicated by the completed tests. The aggressive action to develop the test procedures and complete the testing was initiated at 1500 on July 19, 1989 during a special meeting of the Plant Review Committee.

Technical Specification LLRT acceptance criterion is 65,200 cc/min.

Special test criterion is approximately 6,500 cc/min per penetration pipe.

Three tests (penetration) have been completed. Leakage was 18, 435 and 8.8 cc/min respectively.

While not tested at full.design pressure, the lines are routinely pressurized at 10 psi during monthly I&~ calibrations of associated pressure switches and transmitters. Prior calibrations have not identified leakage problems prior to the 18 cc/min identified with MV-1805.

Past ILRT performances have successfully been completed for portions of the associated piping which in fact, exceeds analyzed design accident pressures.

LLRTs have been successfully completed on all inboard containment isolation valves associated with the piping penetrating the containment at both penetrations 17 and 48.

Total containment leakage identified during the 1988 ILRT was 0.01650 wt

%/day. This value represents 31 percent of the total allowable leakage.

OC0789-0157-NL04

Nuciear Regulatory Commission Palisades Plant Request for Enforcement Discretion July 21, 1989

• 5*

A preliminary calculation has shown the maximum leakage which would be expected from a guilotine break of an.instrument line to be 92,000 cc/min if containment was at design pressure. Even with this leakage, the resultant dose would only be a fraction of 10CFRl00.11 limits. This is based on:

PCS leakage being under 0.1 gpm PCS activity being only two percent of Technical Specifications allowable Palisades MHA dose (FSAR 14.22) is 69.7 rem to the thyroid and 0.975 rem to the whole body. Containment leakage contribution of this dose is 42.9 and 0.899 rem to the thyroid and whole body respectively. This assumes 55 psi in containment, a Regulatory Guide 1.4 source term and maximum allowed containment leakage.

A review of other containment penetrations was completed and the problem was determined to be an isolated case.

If testing is not successfully completed, the Plant would enter Technical Specification 3.03. This would require the Plant to be in the hot standby condition within six hours and in the cold shutdown condition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

If shutdown was initiated, Technical Sp~cifications would allow 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to reach cold shutdown, while the remainder of testing is expected to only take 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> (based ori a 1200 NRC conference call).

We procedurally cannot enter containment during transient conditions for worker safety. Therefore, if shutdown was initiated, testing would have to be stopped.

Generic Letter 87-09 states, "special circumstances may require additional time to ensure that the surveillance can be conducted in a safe manner *** "

the time limits of the Action Requirements are applicable either at the end of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit if the surveillance is not completed or at the time the surveillance is performed if the system or component is found to be inoperable.

The NRC established a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> criteria in Generic Letter 87-09 based on the fact that most surveillances prove the systems are operable. The time limit is based on considerations of Plant conditions, adequate planning, availability of personnel, time required to perform the surveillance as well as the safety significance of the delay in completion of the surveil-lance. PRC has concluded that the Plant is in safer configuration to remain stable and complete the testing (three of eight done successfully) rather than start a shutdown which will delay the completion of the testing and create a transient in the Plant.

OC0789-0157-NL04

Nuclear Regulatory Palisades Plant Co~sion Request for Enforcement Discretion July 21, 1989

• 6 If any test fails to meet the Technical Specification acceptance criterion for leakage (ie, 0.6 L ) of 65,200 cc/min, an immediate Plant shutdown will a

be initiated. This .. is conservative in light of Technical 'Specifications which allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to repair and retest any penetration which exceeds 0.6 L

• a Reasons Testing in a Shutdown Condition Would be More Prudent:

ALARA: We are receiving some radiation exposure, however, expected exposure is 400 mRem.

Industrial safety, however, we have enough personnel to rotate.

All local leak rate testing was completed at 1955 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.438775e-4 months <br /> on July 20, 1989. The total leakage rate for all eight penetrations was approximately 1,000 cc/min. An Event Report (plant corrective action document) has been initiated which will address containment isolation classification and testing of all components associated with penetrations 17 and 48.

Thomas C Bordine Plant Licensing Administrator CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0789-0157-NL04