ML18058A308

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-255/91-19

ML18058A308
Person / Time
Site:	Palisades
Issue date:	03/26/1992
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9203310014
Download: ML18058A308 (20)

See also: IR 05000255/1991019

Text

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MAR ~ 6 1992 D.ocket No. * 50-255 . . . Consumers Power Company ATTN: * Mr. Gerald B. Slade .*General Manager Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI * 49043

De.ar Mr. Slade: SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-255/91019(DRS)) This will acknowledge receipt of your letter dated March 2,. 1992, in response to our* letter dated January 31, 1992, '

. . transmitting a Notice of Violation associated with In~pection

• Report No. , 50-2?5/9l019 (DRS).* This report summarized the results

of an electr.ical distribution system functional inspection (EDSFI). at your Palisades Plant. We hav~ revi~wed your corrective actions and. have no further questions at this time~ These corrective actions will be examined during future ipspections. Enclosure: Letter dated March 2, 1992 See-Attached Distribution RIII~ RI~g~r'- . (J.f\\ fr: Neisler/jk. Jorgensen 03/25/92 0312.l f 92 RIII ~.l\\ 1- Gardner Sincerely, Original signed by G. c. * Wright (for) H. J. Mille~, Director Division of Reactor Safety RIII ~-

• Ring

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Consumers Power Company Distribution cc w/ericlosure: David P. Hoffman, Vice President * Nuclear Operations P. M. Donnelly, Safety and Licen~ing Director DCD/DCB (RI.OS) OC/LFDCB ~esident Inspector, RIII James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Brian Holian, LPM, NRR SIU, Big Rock Point E. Imbro, NRR w. Hodges, Region I J. Durr, Region I A. Gibson, Region ~I c. Julian, Region It* s. Collins, Region IV T. Stetka, Region IV R. Zimmerman, Region V D. Kirsch, Region V 2 M.D.R 2. G 1992

,**

' .. . , consumers * Po.wer POWERING MICHIGAN-S PROGRESS Palisades. Nuclear Plant:. 27780 Blue Star Mem~ial Highway, Coven. Mi ,49043 .*March 2, 1992 Nuclear Regulatory Convnission Document Control Desk Washington, DC . 20555 . GB Slade G~Mra/ Manag~r . DOCKET 50-255 - LICENSE* DPR-20 - PALISADES PLANT - REPLY TO NOTICE OF VIOLATION AND REPLY TO NOTICE OF. DEVIATION; NRC INSPECTION REPORT No. 91019 NRC Inspection Report No. 91019 provided the r~sults of the special electrical distribution system funct1onal inspection (EDSFI} of the Palisades Plant. The inspection report* identified apparent violations and deviations from NRC reqoirements. Our response to the violations a~d deviations is provided in the attachments to this letter. The inspection report also identified a riumber of open items and unresolved items and requested a reply to those items as well~ As was discussed with Mr. Bruce Jorgensen of Regi*on II I staff and Mr. Pat

• Donnelly of our staff, on February 12, 1992, a reply to these issues will be

provided by March 31, 1992. .

• with regard to the design vulnerabilities that the inspection team identified,
• we will consider appropriate measures to address these vulnerabilitie~. With

regard to the issues related to the seismic capabilities of plant equipment, which are being ass~ssed unde~ NRC Generic Letter 87-02, we will strive to ~ake meaningful improvements to plant nuclear safety in .this area. We are cognizant

• of the many other iSsues and concerns raised by the inspection and are pursuing

resolutions to them consistent with their relative priority. If you should so desire .we will provide a status of our. efforts whenever it is mutually ~onvenient.

• *

~3 Gerald B Slade General Manager CC Administrator, Region Ill, USNRC NRC Resident lnsp_ector - Pali sades Attachment 1 Reply to Notice of Violation Attachment 2 Reply to Notice of Deviation A OW5 NE7?GY.COMPANY M.~R 5 1992 MAR 5 1992

. *.CONSUMERS POWER COMPANY. To the best of my knowledge, foformation and belief, the contents of this . submittal ar~ truthful and complete. ~** David P Hoffman, Vic .Nuclear Operations Sworn and subscribed to before me this ~day of ~* 1992. * ~L~**.* .. .* ~ . . NatarYUbiic. * . . . My commi SS ion expires . BEVERLY.NIN AVERY . NOTARY PUBLIC-JACKSON COUNlY. Ml MY OOMMISSION EXPIRES 12-1-92 \\:

ATTACHMENT. 1 Consumers Power Company Pali~ades Plant

. Docket 50-255 . REPLY TO NOTICE OF VIOLATION INSPECTION REPORT No~ 91019 March 2, 1992 10 Pages .. :*,

. 1 . REPLY TO NOTICE OF VIOLATION Violation 1 10 CFR 50, Appendix 8, Criterion III, requires that. applicable regulatory requirements and the design basis be* correctly transl.ated into drawings, * procedures and instructions. Criterion III a1So requires that design change~ .be subject Jo design control measures commensurate with the or.iginal design.

ca*ntrary to. the above, from Harch 1986 until .December 13, 1991, the licensee . failed to translate a design change, which re-sized 17 thermal overloads associated with safe.ty related motors,. into field instructions for implementing the changes. *

• *
• *

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.. Reason for the Violation _ The reason for the discrepancies found between install~d overload heate~s and those specified in the setting sh~ets for motor control centers (MCCs) No; 1 and No. 2 was procedure inadequacy. System Maintenance and Construction Services ( SM&CS), a section of * the Consumers Power Company corporate * Jaboratory, 1 aboratory procedure P0-11, nTest Pro*cedure for Molded Case circuit' Breakers, II Revi.sion 7-1985, used for testing of molded case circuit breakers; did. not require.SM&CS personnel to compare installed equipment with that specified in the settin~ sheet.

. . . . . . . .* Breakers within MCCs No. 1 and No. 2 were tested by SM&CS personnel in 1986. - Breaker testing was performed in conjunction with the plant .electrical maintenance department's preventive maintenance of the-breaker buckets. During the bucket preventive maintenance, the breaker was removed from the bucket by electrical maintenance and given to SM&CS for testing. Upon completion of testing, the breaker was returned to the plant electrical ~aintenance department. for reinstallation i~ the bucket.* In 1986, SM&CS personnel were not explicitly required by the SM&CS procedure ( PD-11) to verify that the settings of protective devices 1 isted on the setting sheet (e.g., starters, breakers, -overload heaters, . etc.) matched those i nsta 11 ed- in the bucket. Based ori information provided by SM&CS personnel who performed the breaker testing in 1986, the verification of protective devices listed on the-setting sheets was .considered an SM&GS responsibility .. However, this verification was apparently not performed i.n this instance. Furthermore, System Protection Engineering did not provide the revised setting sheets to the plant. In 1986, the method by which the plant would have been notified of an* equipment discrepancy was through a deficiency_ notice generated by SM&CS personne 1 during breaker testing. No deficiency notices have * been located for MCCs N~. 1 and No. 2 from 1986 testing. Thus, plant personnel were not aware of the equipment discrepancies. Absence of the deficiency notices also supports the belief that a comparison between installed and required* equipment was not performed . D .* .;.

2

• Additional mearis now ~xi st to pr~verit ins~alled equipment from going unnotjced

and unchanged from that specified in the setting sheet. Upon issuance of setting or equipment changes by System Protection Engineering, the plant Systems

• Engineering Department receives an information copy of the revised setting sheet

which no.tes any changes. This serves to notify the plant of changes jn overload . heater sizing and allows for these changes to be made via the work order process prior to SM&CS personnel c_oming onsite to test the device .. Corrective Actions Taken and Results Achieved 1. Provide walkdown verification of setting.* sheet specifications for MCCs located inside containment. For Safety Related MCCs operability.* determinations will be made for discrepant information. . . 2 .. A.11 MCCs .1 ocated outside of containment have. been wa 1 ked down for component. verification. These results will be utilized to i~plement actions to ensure* .plant equipment matches the setting sheet specifications. For Safety R~lated MCCs operability determinations will be made for discrepant information. Corrective Action to Avoid Future Non-Compliance . . . . . . - The procedure for the testing of molded case circuit breakers, po.:11, "Test. Procedure for Molded Case Circuit Breakers," was ~evised. in 1~89 to explicitly require SM&CS -personnel to verify that installed protective devices (e.g.,

• breakers, starters, overload heaters, etc.} match those specified by the setting

sheet. (This requirement *xists in the 1991 revisio~ of the procedtire.} The verification requirement should prevent equipmerit discrepancies* from being overlooked during future breaker testing. .

Date of Full Compliance Full comp*liance will be achieved with replacement of thermal overload heaters or. when revision to setting sheets has been made. This is currently schedu*led for completion by June 1992. Violation 2 ' ' 10 CFR 50, Appendix.B, Criterion XI, requires that a test program be established to assure that all testing requi.red to demonstrate that systems and components will perform~atisfactorily in service is identified and performed in accordance* .with written test procedures. Contrary to the above: * a. Prior to Decemb*er 13, 1991, the licensee failed to establish a program to periodica11y test the ability of each safety related battery charger* to deliver rated output current and supply a11 require~ loads fo11owing

• a design basis accident (OBA) .

• ***

3 Reason for Violation-2a The reason for this viol~tion is that we faiied to recognize the need.to dev~lop.

• a .program to periodically* test the capacity of the battery chargers.

Technical specifications section 3.7 basis states: "Each battery has two battery chargers available rated at 200 amperes* each. Except for the first minute following a OBA, the capacity of the two battery chargers will handle all required loads.". However, technical specifications section 4.7 does not contain a requirement for testing the battery charger capacity.

. During battery surveillance testing, the battery chargers typically operate at .or near their maximum current rating for the battery equalizing portion of the test. While these tests do . not include any acceptance criteria for .charger performance, they do provide a means for detecting charger* performance degradation.

Corrective Actions Taken and Results Achieved ,. No immediate actions has been taken. Corrective Actfriri to Avoid Future Non-Compliance . ~ . - . ,. . . - . . . : .. Develop and implement a test program that periodically verifies that the battery chargers ~ill p~ovide rated output c~rrent for an appropriate period of ti~e~ Procurement ~f test equipment'and development of a test procedure is required; Date of Full Compliance An outage wi 11 be required to test the battery chargers for rated output current . . Preliminary plans are to procure equipment, develop a test procedure, and conduct the capacity test by the end of the 1993 Refueling Outage. Violation 2b 10 CFR 50, Appendix 8, Criterion XI, requires that a test program be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures.

Contrary to the above: b. Prior to December 13, 1991, the licensee failed to satisfactorily

• demonstrate in post modification testing, the proper operation of the
• control functions associated with contacts 3/3C, 4/4C, 5/5C, .and 11/llC *

located on hand switch HS-152-106RLTS .

.4 Basis for Disputing Violation 2b

• Following* the EDSFI exit meet1ng on December 13, 1991, an in-depth review of the

documentation package for facility change '(FC) 687, nAdd Local/Rem6te Transfer Switch to Breaker 152-106," was performed. Completed test procedure T-FC-687- 001, nTesting of New Fuses and Remote/Local Transfer Switch for Breaker 152-106," which was completed in 1987, indicates that the contacts identified in the apparent violation were properly tested. Therefore, we believe a violation does not exist. The documentation package for FC-687 is available for review at your convenience. The violation states that 'c_ontatts 3/3c, 11/llc, 4/4c, and 5/5c oh ttand switch HS-152-106RLTS were not verified in the post modification test. However, a review of the working copy of the test procedure indicates that contacts 3/3c and 11/llc were verified to operate properly in both the open.and closed position and contacts 4/4c and 5/5c were verified in the closed position. Contact 3/3c was verified in the open position in Step 5.12 of the procedure and verified in the closed position in step 5~40 of the procedure. Contact .11/llc was verified in the open position in Step 5. 27 of the. procedure and verified in the closed posit.ion in* step 5.29 of the procedure. The working copy of the test procec:lure shows that the procedure steps which accomplished the veri fi cation were coinp l eted on October 25, 1987.

Contacts 4/4c and 5/5c were verified closed in Step 5.35. This step checked for loss of indications on* the meters .. These contacts were*not verified open in the procedure as this position results in the meters receiving required power and* currerit. Plant operators look at these meters on*a daily basis and through their * observations have repeatedly verified that th~ contacts are ~pen. * . The test discrepancy lies only fn the fact that normal indication of the meters* was not recorded in the test procedure. However, this is a task.that plant operators perform on a daily basis. Therefore, all contacts were properly tested in both positive and negative logic. There was rio evidence of improper testing techniques. -

Violation 2c 10 CFR 50, Appendix.8, Criterion XI, requires that a test program be established

• to assure that a11 testing required to demonstrate that systems and components

will perform.*satisfactorily in service is identified and performed in accordance with written test procedures. Contrary to the above: c. Although required-* by modification FC-839, completed in 1989, the licensee failed to test whether the low suction pressure and low lube oil pressure trips were blocked when charging pump "B" was fed from the alternate power supply.*

. , ** 5 . Reasori for Violation. 2c The reason for ttie inadequate post modification test procedure was an incomplete* _ post modification test procedure.

. . . . . . . . . . . . .- . . . . . . . Review of the faci l i ti change {FC) package for FC-839, "Modify 480V Power Sources* to provide feed to P'-SSB from either IC or 10 Bus," was performed. It was determined that there were no steps in the modification test procedure (T-FC-839~1) that directly checked whether the low suction pressure and the low

• lube otl pressure trips on charging pump P-SSC were blocked from tripping the P- *

SSC brea~er when this breaker was used to power charging pump P-SSB. Blocking . of the low lube oil pressure trip for this condition (P-SSC breaker powering P- . 55B) was checked .indirectly by T-FC-839-1 in that P-SSB successfully ran when

• powered from the P-SSC breaker.

Since P-SSC was not running at this time,. it . would have h~d a lo~ lube oil pressure trip signal initiated which ~as blocked from tripping the P-55C breaker. However, no check (either direct or indirect) . of the block of the low suction pressure trip was performed.

. . . Corrective Actions Taken and Results ~chieved Engineering guidelines have been developed to augment the administrative procedure for facility changes (AP 9.03). The .administratiVe procedure and_ . engineering guidelines assure that (1) appropriate testing has been specified, (2) test boundaries are well defined.and (3)_justification has been provid~d for any portion of the system not being tested..

. . . . The fo 11 owing t~sts will be performed to comp 1 ete the negative 1 og i c testing: 1. With P-55B running on P-55C power source, simulate a low lube oil pressure and low suction pressure trip of the normal source P:-SSB contact to show that they will not trip the* pump. 2 ... With P-S5B running on its normal source: a. Simulate a trip of the same above contacts and show that they will trip the pump. b~ Simulate a tri~ of the other set of low l~be oil pressure and low suction pressure trip contacts to show that they will not trip the pump.

A sampling of recent modifications will be reviewed to verify that appropriate testing was performed on previous electrical modifications. The review s_hould verify that both positive and negative logic testing was performed. If testing was incomplete, further remedial action will be proposed for retesting. We will also determine if further review of modlfications testing is appropriate.

• Corrective Action to Avoid Future Non-Compliance

With the changes made to AP 9.03 arid appropriate corrective action in place; no further actions are necessary. ..

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. 6 Date of Full Compliance Full compliance ~ill be achieved with the completioD of the ~esting described above, which is scheduled for Septe~ber 1992~ Violation 2d 10 CFR 50, Appendix B, Criterion XI, requires that a test program be estab1 ished. to assure that a11 testing required to demonstrate that systems and components wi11 perform satisfactorily in service is identified and performed in accordance with written test procedures.

Contrary to the above: d. Prior to December 13, 1991, the monthly emergency diesel generator test method failed to demonstrate the ability of the diesel generators to accept Toads within the required time. *

• , .

Reason for Violation 2d

• Failure. to account for relay actu~tion times when determining* adequacy of *

emergency diesel generators start time. TechnicalSpecification 4.7.1.a states J ~~. ~*,.. . that "Each diesel generator shallbe manually started each month and demonstrated , to be ready for loading within 10 seconds. The signal initiated to start the diesel shall be varied from one test to another to verify that A and B starting . circuits *re operabl~. The* generator shall be synchrohized from the control room* and loaded to 2400 +/- 100 KW."

Palisades has consistently interpreted this requirement as pertaining to the ability of the diesel engine ~o accelerate the generator and the -voltage regulator to. flash the field such that the breaker closure permissives are met

• within 10 seconds.

DISCUSSION OF DESIGN AND TESTING PRACTICE . . For a diesel generator tQ automat i ca 11 y start and be ready to accept 1 oad at Palisades, a series of relay actuations must occur. Following the diesel engine star~ and the buildup of generator voltage, additional relay attu~tions must.* occur for the diesel to take on load. Finally, the diesel generator output breaker must 'close for the diesel generator to be synchronized t_o provide power.

• .Bus undervoltage re 1 ays sense and actuate*

Undervoltage auxiliary relays actuate

Diesel gerierator start relays a~tuate

Engine Start relays actuate

Cranking Relays actuate .

Air Solenoid Valves act~ate and open

The engine. cranks and fires. The generator field flashe_s for voltage buildup.

Dies~l Generator Voltage Check relays senie and actuate

7

Power FaHure Relays Actuate**

Oie~el generator output breaker closes As discussed* in the EOSFI. inspection *report, our current testi*ng method determines the time from actuation of the air solenoid valves until the time that* the generator voltage. check relay flags drop. We do not time upstream or downstream relay actuation times, rior is this time accounted for* in the acceptance criteria of the surveillance test. However, the accident analysis . does make allowances for a 1 second signal processing delay, in addition to the allowed 10 *econd starting time for the ~iesel ge~erators. - DISCUSSION OF INCLUSION OF RELAY DELAYS- IN DIESEL GENERATOR STARTING TIME It is appropriate from a technical poi~t of view t6 include signal .processin~ delays either in the start time measurement of the diesel generators or in the ac~ident analysis .. The original purchase specification for our diesel generators required that the equipment supplied by: the diesel generator vendor be capable of accelerating and exciting the volta~e regulator to a]low loading within 10 seconds. Therefore, it is not appropriate to add actuation of other devices in to the 10 second starting time; however, these delays should be accounted for in the accident analysis. The* original basis for the assumed 1 second. delay was established by analysis associated with the core 2 relOad (late 1970s} and on the plant design at that time. The auto start logic for the diesel generators has . changed significa~tly, however, the basis for the 1 second assumption has never been revised. Furthermore, no confirmatory tests or analysis have been performed to. validate the assumptions. Such an effort is warranted and will be undertaken. . . The equipment supplied by the diesel generator vendor includes the engine start relays (ESRl, ESR2}", the cranking relays (CRl, CR2}, the engine and generator, and the generator voltage check relays (127D-l} .. It is appropriate to verify * that the actuation of all these components such that the diesel generator is ready for loading within 10 seconds. However, as stated previously, our current testing methodology does not test the performance of the engine start relays or. the cranking relays. Prior to Revision 25 of .techniCal specifications surveillance procedure (TSSP} M0-7A-l and Revision 26 of TSSP M0-7A-2; the testing methodology wa$ to tinie from actuation of the manual control sw.itch until 2000 volts was .reached-as indicated by panel meters. The above revisions to the TSSPs redefined the start time as the time from actuation of the manual control switch until the flags dropped on the generator voltage check relays. (This methodology still .included ESR and CR actuation times*.} These changes were .incorporated.in response to lengthening start times. However, due to problems associated with beginning the start time measurement in the control room and ending the start time by observat.ion of indication at the diesel generator, minor revisions were made to the TSSPs. These minor revisions initiated the start time w.ith *actuation of the* air soleno.id valve at the* diesel generator whiCh ef feet i ve 1 y removed measurement of ESR and CR re 1 ay actuation ti me from the start ti me. However, the documentation associated . with the TSSP change did not consider this fact. It is appropriate, therefore, to either. reduce the - surveillance test start time acceptance criteria by an amount equal to ESR and CR actuation times or to change the method of obtaining start times to account for these relay actuation times.

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-* 8 DISCUSSION OF THE USE OF STOPWATCH In the discussion of the violation, the NRC stated that the use of a stop watch for determining start times offers the *potential for additional errors. While this is a true statement, we believe that use of a stopwatch is an acceptable

• practice.

Discussions with other personnel throughout the industry indicated that many plants utilize a stop watch to determine diesel generator start times . . We believe that the errors induced by human reaction at the beginning and at the end of the timing cycle will tend to cancel each other, resulting in reasonable assurance.that the resulting starting times are representative. Lastly, use of a stop watch has be*en determined to be an acceptable practice in the testing of . . valve stroke times in the ASHE Section XI testing program.

Corrective Actions Taken and Results Achieved Operability of the Diesel Generators was addressed by a special PRC team which * indepe~dently verified conclusions about equipment operability. Therefore, no other immediate actions were necessary. Corrective Action to Avoid Future Non-Complianie I. Conduct a validated.test or.analysis which verifies that the collective non-* diesel generator component actuation times (bus undervoliage* sensing relay through diesel generator start relays plus generator voltage permiss*ive through breaker closed to the bus) are less than or equal to the 1. second . assumed in the accide~t analysis. Considerati-0n will be given to the need.* for periodic testing of this parameter. This corrective action will be comp 1 eted by June 1, 1992 .. * 2*. Revise. the monthly TSSPs for the diesel generator to account for the actuation times for the ESR and CR.telays. *This corrective action will be completed by August 1, 1992. Date of Full Compliance The above actions will be completed by August l,* 1992, therefore; full compliance will be achieved by that date..

Violation 3 10 CFR 50, Appendix 8, Criterion XVI, requires that measures be established to assure that conditions. adverse to quality are promptly identified and corrected. Contrary to* the above, as of December 13, 1991, the licensee failed to identify and implement adequate corrective action in each of the three instances on where the Technical Specification limit of 750 amps was exceeded during diesel generator surveillance testing.*

9 Reason for the- Vi o 1 at ion After each of the overcurrent events -a corrective action document was initiated, . evaluated and corrective action assigned .. *.In each case _the corrective action was

• conunensurate with the available knowledge of the situation being addressed.

Evaluation of* the Septe~ber _* 1990 *event determi.ned that the diesel* generator was being* operated with abnormally high current for the real .load being carried before the overcurrent condition exhted~ With.diesel generator current ~lready being hfgh, it was judged that bnly a .small change in grid voltage was enough to cause the overcurrent. *since-there* was no * reaCt i ve * load 1 ndi cation, the corrective * action was - to . , administratively limit output current in relation to re~l'.load. so that the generator was being operated well belbw the Technical _Specification * * limit. *

• * After the December 1990 event; .a suspected cause of exceeding 750 *amps
• was corrected with the cleaning. of the automath: voltage regulator

potentiometer. Testing in February 1991 indicated that the voltage regulator responded properly to changes in the off-site power transformer tap changer position. At that time it was concluded that the root cause of e~ceeding 750 amps had been found and ~orrected:

Evaluation of the September 1991 event resulted in a more prob~ble root cause. Interim corrective action has been implemented to further administratively limit diesel generator output current and *to provide . additio.nal operator training. Further_ corrective action has .been identified, but not yet implemented. The testing identified as a result of this evaluation requires an outage to be .performed and the needed . engineering evaluation requires updating of the computer model. Updating - of the engineering-evaluation is scheduled for completion in June 1992. Based on the intermittent occurrence of the overcurrent condition and the lack. of identifiable causes found by testing, the corrective action taken was appropriate for ea_ch event. . - Corrective Actions Taken and Results Achieved The overcurrent condition identified in the violation results from operating th~ diesel generator in parallel with the off-site power transformer. This overcurrent condition does not occur when the diesel generator is operated in the synchronous mode. Since the diesel generator would normally operate in the synchronous mode in the event of a diesel generator actuation, the safety function of the diesel generator is not compromised and would be capable of fulfilling its design function.

As a result of the Diesel Generator 1-1 trip on ~eptember 17, 19~1, previous cor~ectiYe action documents associated with overcurrent anomalies on the diesel g~nerat~r were reviewed. Extensive evaluation of the effect on diesel generator electrical equipment was performed and showed no defective equ1pment. * In addition, computer modelling was employed to study the .2400V system during

. , .* 10

• .several postul~ted conditions when Diesel Generator 1-1 was

int~rconnected to Safeguards Transformer 1-1. The results of the computer mode 11 i ng *indicated fhat everi with administrative limits on. the diesel generator phase current, the

• .possibility of an overcurrent situa~ion due to VARS still exists.*

We have concluded that the September 17, 1991. corrective* action document adequately addresses the concerns regarding diesel generator testing and no further evaluation is necessary~ Corrective Action to Avoid Ftiture Non-Compliance An engineering evaluation will be performed to a 11 ow manual operation of the 1-1 Safeguards Transformer tap changer during parallel operation with the diesel .generator. The voltage droop on each diesel .generator will be measured during testing which will be conducted June 30, 1992. It is our intent to request a change to Technical Specification 4.7.ld to provide clarification. This change request will be submitted on a priority consistent with other planned changes to the. Technical Sp~cificatioris. Date of ~ull Compliance Ftill compliance for testing and analysis will be achieved by June 30, 1992. .*.*.

ATTACHMENT 2 Consumers Power Company , Pa 1; sades Pl ant Docket 50-255 REPLY TO NOTICE OF DEVIATION INSPECTION REPORT* No. 91019 March 2, 1992 4 Pages .. . *_:,,

1 REPLY TO NOTICE OF DEVIATION .. Deviation 1 FSAR Section 8.4.1.3 states that each emergency diese1 generator (EOG) has two separate independent starting motors and to assure re1iabi1ity, each EOG has two independent start circuits on separate de sources. Contrary to the above, on December 13, 1991, the team identified that the start circi!its were not independent sf-nee a loss of the "B" start circuit or loss of the . field. flashing unit would prevent the emergency diesel generator from starting within the required 10 seconds.

Reason for the Deviation* The current description of the diesel generator start circuits contained in the FSAR is the same as it was when the original FSAR was developed .. The words used.* are ambiguous in that they may be interpreted to mean that the starting circuits are identical and redundant. Actually~ the startfng ~ircuits are redundant only to the degree that they will both properly engage and disengage the air start * motors. However, they differ significantly in that the B start circuit provides field flashing while the A start circuit provides alarm and trip functions, but not field flashing.

• *
• *

The original purchase speCification for the diesel generator required dual electric cont'rol circuits only for the air start motors. * The diesel engine supplier provided two start circuits as a simple method of enhancing reliability -by assuring that an engine would be able to crank if one of the DC supply breakers failed. Channel (circuit) separation is maintained through separat-ion and redundancy of the two start circuits associated with Diesel Generator 1-1 * with. respect to the two start circuits associated with Diesel Generator 1-2. . - . . . . . . . . Palisades has made a practice of considering a di~sel generator inoperable if one of the start circuits is failed. However, we have performed an analysis . associated with a corrective action document (E-PAL-91-025) which determined that a diesel generator is capable of performing its safety function should start circuit A fail. The analysis for.the start circuit A failure was. performed in respo~se to an inadequate electrical design of the anriuriciatiori associated with the start circuit A.

• * *

There are no requirements in any design basis document (e.g., IEEE standards, Reg. Guides, etc.) which require separate and redundant start circuits for a diesel generator. The information in question was included in the FSAR as descriptive material only. Corrective Actions Taken and Results Achieved No immediate corrective action is proposed.

2 Corrective Action to Avoid Future Non-Compliance. The FSAR will be revised to clarify the intent of the statement on independent start circuits. ' ' ' Da~e of. Full Compliance . Full compliance wtll b~ achieved with a revision to the FSAR .. Deviation 2

• FSAR s*ection 8.-4.1.3 states that each Diesel Generator -(l)G) is provided with a

remote "Contro'1 Switch Not in Automatic" alarm in. the control room. Contrary to the above, as of December 13, 1991, with the diesel generator . remote/local transfer switch in "Local," there was no alarm indication. in the control room to notify the operator that the capabi1 ity of the diesel generator to- start automatically is defeated. Reason for Deviation The reas6ns for this deviation are:

Misinterpretation of information exchanged between the NRC and CPCo * during evaluation of SEP topic VIII-2.

Failure to adequately implement an NRC commitment via SFC-80-128 and SfC- 80-lZ9. * . .

Inappropriate inclusion of the statement in the FSAR.

Failure to explicitly consider the requirements* of IEEE 279-71, Reg. Guide 1.47, and Branch Technical P_osition (BTP)-PSB-2 during the design and implementation of Fc.:639.

.-Th.rough the Systematic Evaluation Process (SEP) we committed to the requirements of IEEE 279-1971, Reg. Guide 1.47, ~nd BTB-PSB-2 with respect to indication of conditions which cause a diesel generator to be unabl~ to ans~er an a~tomatic demand. The,current design only marginally meets these requirements.

This design basis, which we have committed to in the FSAR, Section 8.1,. is paraphrased below from BTP-PSB-2:

2 .1 Del iberate1y induced bypass or inoperabi1 ity status for EDGs should be automatica11y indicated *in the control room for conditions which are expected to occur more frequently than once per year. For conditions expected to occur less frequently than once per year, manual indjcat.ion is considered adequate. . 2.2 All status indication should be sufficiently precise to prevent

3 misinterpretation. Further, disabling or bypass indicators should. be separate from non-disabling indicators. The alarms should be displayed.both 1oca77y at the EDG and.in the.control room, with wording that indicates that* the EDG is incapable of automatica77y responding to a demand. *

ADEQUACY OF EXISTING DESIGN The existing design does not explicitly conform to the requirements of the existing licensing design basis .. Conditions exist which may render the diesel generator incapable of responding to an automatic demand ~nd are not annunciated . in t_he control room. This condition exists (l) when HS-G20/Remote/local Transfer Switch (RLTS) or HS-152~107/RLTS is in* the "local" position and (2) may exist . when the voltage regulator switch is in the "manual" position.* Furthermore, the existence of the "Engi~e Ready" indicating.light above the co~trol room engine

• start/stop control switch may provide confusi.ng information to operators under.

certain conditions. . . The design of the Rl TS was acce'pted by the NRC vi a an SER conducted for FC-639, "Install Isolation Switches on lC Engineered Safeguards Bus and 1-l DG,"_dated . January 29, 1986. In addition, BTP~PSB'-2 indicates that manually* induced indication is adequate for diesel~generator unit bypass or inoperability status for those conditions expected to occur less frequently than once per year. Operation of. the RLTS is such a condition. The switches are periodically. (currently every three years) tested by Special Test T-280. Furthermore~ since the purpose.of the RLTS is to isolate critical equipment from .fire damaged . equipment (the control room *in this case), it is not logical from a design perspective to.have an alarm annunciated in a locatio.n which is being isolated. Positioning of HS-G-20/RLTS in the "local" position will result in loss of the "Engine Ready," "Engine Running," and "Engine Cranking" indicating 1 ights in the control room. (These are located above the control. room control switch .for *.*

• Diesel Generator 1-1.) This provides basic indication of mis-positioning of the

control ~witch~ Similarly, positioning of HS-152~107/RLTS in the local position results in the loss. of the diesel generator output breaker '(152*"107) open and .closed indication in the control room. *

Piacement *of the ~oltage regulator hand switch in the manual position may make -- the diesel genetator unable to automatically respond to an*automatic demand. The position of the voltage regulator Automatic/Manual control switch is indicated by lights in the control room at the switch on control room panel C-04, not by alarm as suggested by the licensing design basis .. . The "Engine Ready" light above the control switch located on control room panel C-04 may provide confusing information to operators under certain circumstances. If the engine was to trip due to generator differential action or overcurrerit, both the breaker trip and start signal blocked alarms would annunciate; however, the "Engine Ready" light would remain illuminated: Similarly, if the engine was to trip on overcrank, the fail to start and start signal. blocked alarms would annunciate; however, the "Engine Ready" light would remain illuminated. Finall~, if control power was.lost to start circuit e~ the start signal blocked

• alarm wo~ld annuriciate in the control room; however, the "Engine Ready" light

.'*(*

4 would remain illumin~ted. C~nversely, if DC power was lost to start circuit A, the start signal blocked alarm would annunciate, and the ~Engine Running" light would. not be illuminated; however, the. engine would. be capable of responding automaticall~.

• *

The.se conditions may provide the operations staff with conflicting a*nd confusing information which does not comply with the licensing. design basis. Corrective Actions Taken and Results Achieved No inunediate corrective act_ion is proposed.

• Corrective Action to Avoid Future Non-Compliance

1. Complete a ~eview of all diesel generator process parameters, indication and alarms to determine the necessity for modifications. This review will* explicitly consider.the issues identified in this evaluation. This acti~n will be completed by May 15, 1992 2. Perform testing and/or analysis to determine if the diesel generator is capable of responding to an automatic demand with the voltage regulator switch in the manual position* and/or the unit-parallel switch in the parallel position. This activity will be completed by May 15, 1992. . . - . - . 3. We will initiate modificatiQns resulting from the above evaluations by August 15, 1992. Implementation of any proposed modifications will occur through the normal modification planning process. 4. If additional testing is necessary, it will be performed during the 1993 refueling outage. Date of Full Compliance Full ~ompliance will be achieved upon completion of modificati~ns identified above.

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