ML18058B676
| ML18058B676 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/22/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303020273 | |
| Download: ML18058B676 (7) | |
Text
consumers Power *
- POWERING MICHIGAN"S PROGRESS Palisades Nuclear Plant:
2778~ Blue Star Memorial Highway, Covert. Ml 49043 February 22, 1993 Nuclear Regulatory Commission Document Control Desk Wa~hington, DC* 20555 GB Slade Genera.I Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT
~ REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT No. 92028 NRC Inspection Report No. 92028, dated January 21, 1993, forwarded the results of the NRC inspection condutted from December 7 through 18, 1992.
The areas examined during the inspection w~re prima~ily a review of the Palisade~
program for inservice testing of pumps and valves established in response tri Generic Letter 89-04 and of the effectiveness of the program for monitoring the performance of check valves.* The inspection report identified an apparent violation of NRC requirements pertaining to inadequate acceptance criteria to verify that certain check valves were exercised to their full open position.
. Our reply to the Notice of Violation is provided in the Attachment to thi~
-letter. *
-~ff~~
Gerald B Slade General Manager CC: Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment
~
9303020273 930222
~DR. ADOCK 05000255
. PDR A CM5 ENERGY COMPANY IE.o I I '
f ATTACHMENT Consumers Power Company Palisades Plant.
Docket 50-255.
REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT No; 92028 February 22, 1993 5 Pages
REPLY TO NOTICE OF VIOLATION Violation Technical specification 4.0.5.a states "..* inservice testing of ASME Code Class 1, 2, and 3 pumps and valves sha71 be performed in.accordance with Section XI of the ASME Boiler and Pressure Vessel Code *.. "
ASME Section XI, IWV-3522, "Exercising Procedure," states, in part; "check valves sha71 be exercised to the* position required to fu7fi77 their function... "
Contrary to the above, inservice Jest procedure Q0:...88, ["ESS Check Valve Operability T~st"] :dated.October 2, 1992 [October 2, 1989], contained.
inadequa.te acceptance criteria to verify that the fo71owing check valves were exercised to their fu1J open position (50-255192028-01 (DRS));
- a.
Primary coolant Toop check valves CK-ES3101, CK-ES3116, CK-ES3131, and CK-ES3146 required 8000 gpm flow to verify full open, whereas the test acceptance criteria was 1200-1800 gpm.
b,.
Low pressure safety inject i_on check va 7ves CK-ES~l03, CK-ES3118, CK-ES3133, and CK-ES3148 required 1600 gpm flow.to verify fu71 open,
. whereas the. test acceptance criteria was 1200-1800 gpm.
Reason for the Violati~n 1
Circumstances leading to thi_s violatio~ appear to have come.from the following two sources:*
During the initial ~evelopment of Q0-88 for use as a valve test procedure, and when the periodic review for Q0~88 was performed on September 4, 1991, the reviewer failed to compare the acceptance criteria in Q0-88 with. the required full flow rates for the PCS loop and LPSI check valves as specified in *the engineering aid, EGAD-EP-01,"lriservice Test Program - Test Table and Valve Reference Flow Rate".
EGAD-EP-01, provides information on the required full flow rates for check valves within the Palisades Valve IST Program.
Secondly, EGAD-EP-01 states that the required full flo~ rate for the LPSI check valves is 1500 gpl)l instead of 1600 gpm_.
The 1600 gpm required flow rate was a new value derived when Accident Analysis Report EMF-91-177 was completed in 1991.
EGAD-EP-01 had not been updated to include.this new flow data and consequently contained incorrect information regarding the LPSI check valves.
This inc*orrect information in EGAD-EP:-01 was used to establish acceptance criteria during a previous revision to Q0-88.
Evaluation suggests that the.
root cause was a failure to* adequately verify the basis for acceptance criteria for check valve testing.
2 Corrective Actions Taken and Results Achieved Based on.review of recent fl ow performance data, as shown in Tables 1 and 2 (atta~hed), fo~ the low pressure safety injection check valves (LPSI) ahd pr.imary coolant system loop check valves (PCS), we believe that these check v~lves would be capable of passing their required full flow rate if needed.
All recently recofded flow rates, for both the LPSI ~nd PCS loop check valves, were within the Q0-8B acceptance range of 1200 to 1800 gpm.
- Flow rates for th~ LSPI check valves obtained in Q0-8B are considered high enough to provide
- an adequate level of confidenc~ that the LPSI check valves would be capable of passing th~ 1600 ~pm required. full flow rate if needed.
In regard to the PCS loop check valves, it has been determined th~t the f~lly open disk position would be achi~ved at a flow rate of about 1900 to 2100 gpm.
Although Section XI discusses valve testing in terms of full flow testing, Generic Letter 89-04,"Guidance on Developing Accepfable Inservice Testing Programs", allows full valve stroke testirig in situatibns where full flow testing is impractical.
We believe that flow rates-achieved in Q0-88 are_
sufficient to ~rovide ah adequate level of.confidence that the PCS loop check valves would also pass the 1900 to 2100 gpm flow rate needed to fully open*
these check valves.
The LPSI and PCS loop check valves are included in the plant preventative*
maintenance program.
The results of the disassembly and inspections performed to date do not identify any concerns with the ability of the PCS loop chec;k valves to pass flow.
Overall, we believe that the current part stroke testing of the LPSI and PCS loop check valves along with their inclusion in a
- disassembly and inspection ptogram provides an adequate level of confidence in the opefational readiness of these check valves.
Additionally, the PCS loop check valves are the same make ~nd m6del as the Safety Injection Tank (SIT) check valves (CK-ES3102, CK-ES3117, CK~ES3132, arid.
CK~ES3147).. Both the PCS loop and SIT check valves are 12 inch swing check valves.
Palisades has 'been granted interim relief from performing full flow testing of the SIT check valves through the end of the Palisades 1993 Refueling Outage.
The NRC interim relief for the SIT check valves concludes that the current disassembly and inspection provides an adequate level of confidence in the operational readiness of the SIT check valves. Since the PCS loop check valves are part stroke tested via Q0-8B, and are included in the valve disassembly and inspection program, and also since the design of the PCS loop check valves is similar to that of the SIT check valves, we believe that the same level of confidence that exists for the operational readiness of the SIT check valvef also exists for the PCS check valves. therefore no additional immediate actions are required.
Corrective Actions to be Taken to Avoid Further Noncompliance
.1.
Q0-88 will be revised to accomplish.full flow testing for the LPSI check valves at greater than 1600 gpm eac.lf~ This revision to Q0-88 will be completed.prior to the Palisades 19~3~Refueling Otitage during when the testing will be performed.
S(**:
~*
3
- 2.
During* the Palisades 1993 Refueling'Outage, we wfll attempt to verify full stroke operation of the PCS loop check.v~lves.using hon-intrusive instrumentation durjng Performance of Q0-88.
- 3.
lf during performance of Q0-88 the r~~ults are in~onclusive, ~relief*
request will be submitted for disassembly and inspection in accordance with NRC Generic Letter 89-04,"Guidance.on Developing Acceptablelnservice Testing Programs," and. further evaluation of full stroke testing of the PCS loop check valves will be completed_to determin~ the best long term resolution.
- 4.
A reverification of the required full flow rates specified in EGAD~EP-01 will be conducted to:
- a.
Ensure that all check valves requiring full flow testing a~e included in the valve testing program;
- b.
Ensure that the correct required full flow rate and basis are listed for each check valve *in the val~.e testing program, and
~.i~
- c.
Ensure that all test procedur~s;~h't take credit for full flow testing state*the correct flow.rates as(~c~eptance criteria.
~-;.
Date When Full Compliance Will be Achieved All required full flow or stro_ke testing' of the LPSI and PCS loop check valves will be attempted during the Palisa~es 1993 Refueling Outage (scheduled to.
begin in June 1993). Since the testing of these check valves requires injection of borated water into the PCS system through the safety injection headers, testing can only be accomplished while in a cold shutdown condition.
Therefore, the Palisades 1993 Refueling will be the first scheduled opportunity to perform such testing. All necessary program changes needed for full.compliance will be completed by July 15, 1993.
PwMMt.,. *.
1
~
- . Ck-3101 H9............................. Units Ft-0.'307A
~**
'9..
T~"--
1
,J.in :0 I 1987 F.O 10, 1987 1750 3
Jul 1~ I 1987
. 1600 4
Nov 06, 1 987 1800 Noy 07, 1987 6
Aug 31; 1988 7 °'t 21, 1988 1480.
9 F.004, 1989 1550
~
Feb QC), 1~
10 Nov QC), 1989 1340 11
~
10, 19'0 1400 12 F'.O 17, 1991 1220 13 H. 30, 1m 1400 TABLE 1 Primary Coolant Loop Check Valve Flow Test Results 3
'5 7-CK-3111)
CK-3131 CJ(-3146 FH)309A FHH11.A.
FHH14A 1400 1400 1400 1300 1:50 1:50 1750
. 1600 1400 1480 1490 1490 1400 -
1400 1300 1350 i3SO 1260 1~
1~
1300 1220 1450 1400 1400 1m 1300
- This table is taken from the IST data base.
performed on these dates for other valves.
the subject ~alves ori these dates.
4 Partial tests were No data was taken for
TABLE 2.
Low Pressure Safety Injection Check Valves Flow Test Results 5
Parameter No.
4 6
8 Men.
Ho.
1 2
~
r:,.
6 9
I (I 11 12 13 Hame
(.~-3 I 03
(.~-311a
. (.~-3133
(.~-3140
.............._ Units ri;;;e*-........
Fl-03074 Ff-1)3091.
Fl-<)~ 114
. Fl-<)~ 14A
,1,m :o. 19fl7 Fitb 10. 1987 1750.
I.JOO I.JOO IJO(J
,lul 19, 1987 1600 1~00.
1:so.
1:so Nov 06. 1967 180(1 1_750 1600 1400 tktv 07, 1987
-k Aug 31, 1988.
():t :1. 1966 1460 1460 1490-1490 Fe.b 04. 1989 1550
.1400 140()
1300 Fi!t1 *09, 19t'9 Nov 09. 1989 1340 1350 1350 1260 Ha, 10, 1990 1400 1350 1350 1300
. Feb 17. 1991 1220 1220 1450 I.JOO Hctr ~o. 1m 1400.
1-l)()
1350 1300 This table is taken from the IST data base.
performed on these dates for other valves.
the subject valves on these dates.
/
Partial tests were No data was taken for