ML18058B712

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-255/92-28

ML18058B712
Person / Time
Site:	Palisades
Issue date:	03/18/1993
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
GL-89-04, GL-89-4, NUDOCS 9303240135
Download: ML18058B712 (9)

See also: IR 05000255/1992028

Text

Docket No.

50~255

Consumers Power Company

ATTN:

Mr. Gerald B; Slade

General Manager

Paltsade~ Nuclear Generating Plant

27780 Blue Star Memorial Highway

• Covert, MI

49043-9530

Dear Mr. Slade:

MP.R J. 8 1993

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SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-255/92028(DRS))

. This will acknowledge rece1pt of your letter dated February 22, 1993; in

response to our letter* dated January 21, 1993, transmitting a Notice of

• violatjon associated with I~spection Report No. 50-255/92028(DRS). This report

summarized the results of the inservice testing of pumps and valves

established.in response to Generic Letter 89-04 at your Palisades.Nuclear

Plarit.

We

ha~e r~viewed your corrective ~ctions and have no further questions

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at this time~ these corrective actions will be examined during fut~re

inspections.

See Attached Distribution

Rill

.. : r

Dunlop/jk

03/17/93

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03/ /93*

. 9303240135 930318

PDR* ADOCK 05000255

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Sincerely,

G. C.

W~ight, Chief

Engineering Branch

Riii

J~ensen

03/16'/93 .

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PDR

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Consumers Power Company

Distribution

cc: David P. Hoffman,

Vice President

Nuclear Operations

cc w/ltr dtd 02/22/93:

OC/LFDCB

Resid~nt Ihspector, RIII

James R. Padgett; Michigan

Public Service Commission

Michigan Department of

Public Health *

• A. Masciantonio, LPM, NRR

SRI, Big Rock Point

. J. Norberg, NRR/EMEB

T~ iobetz, TSS, DRP

bee:

PUBLIC-IEOl

2

MAR 10 199J.

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consumers

Power

..._ ... ,,.. POWERING

MICHIGAN-S PROGRESS

Palisades Nuclear Plant:* 27780 Slue Star Memorial Highway, Coven. Ml 49043

F~bruary 22, 1993

.

,

• Nuclear Regu,.atory Commission

Document Control Desk

Washington, DC .20555

G 8 Slade

General Manager *

DOCKET.!O-i55 - LICENSE nPR-20 - 'PALISADES PLANT

REPLY TO NOTICE OF

. VIOLATION~ NRC INSPECTION REPORT No. 92028

NRC Inspection Report No. 92028, dat~d January 21, 1993, .forwarded the results

, of the NRC inspection conducted.from December 7 through 18,.1992~ The areas

examined during the inspection were primari.ly' a review of the Palisades

. program for inservice testing of pumps.and valves established in response to

.Generic Letter 89-04 artd of the effectiveness of the program for monitoring

.the performance of chetk .valves.

The inspection report identified an apparent

viol at.ion of NRC requirements pertaining to inadequate acceptance. criteria to*

verify that certain check valves were exercised to their full open position.

• Our repl~ to th~ Notic~ of Viola~ion is provided in th~ Att~chment tri this

letter.

-<S-d.~~

• Gerald B Slade

General Manager

CC: Administrator, Region III, USNRC

NRC Resident Inspector - Palisades

Attachment

/ .

• . A ats C/VERGY COMPANY FEB 2 6 1993

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ATTACHMENT

Consumers Power Company

Palisades Plant

Docket** 50-255

.

REPLY TO NOTICE OF VIOLATION

NRC iN.SPECTION REPORT No. 92028

February 22, 1993*

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5 Pages

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• REPLY TO NOTICE OF VIOLATION

Violation

Technical specification 4.0.5.a states " .. . inservice testing of ASME Code

Class 1, 2, and 3pumps and valves sha.17 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 sha77 be

exercised to the position required to fu1fi11. their function ... "

Contrary to the above, inservice test procedure Q0-88, ["ESS Check Valve

Operability Test"] dated October 2, 1992 [October 2, 1989], contained .

• inadequate acceptance criteria to verify. that the fo77owing check va"1ves were

exercised to their fu17 open position* (5{)-255/92028-01 (DRS)).

a.

Primary coolant loop check valves CK-ES3101, CK-ES'3116, CK-ES3131, and

CK-ES3146 required 8000 gpm now to verify full open, whereas the test

acceptance criteria w~s 1200-1800 gpm.

b. * Low pressure safety injection check valves CK-£53103, CK-£53118,

cK:.£53133, and CK~E53148 required 1600 gpm flow to verify fu1J open,.

whereas _the test acceptance criteria was 1200-1800 gpm.

Rea~on for the Vi~lation

Circumstances leading to this violation appear to have com~ from the following .

two sources:

During the. initial development 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-Ol~"Inser~ice 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-E~-01 states that the requir~d ful~ flow rate for the LPSI

check valves is 1500 gpm 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 theLPSI Check valves.

This incorrect information in EGAD-EP-01 was used to,establish acceptance* ..

criteria during a previous revision to Q0-88. * Ev.aluation suggests that the

root cause was a failure to adequate 1 y verify the basis for acceptance

criteria for check valve testing.

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• Corrective Attions Tikan and Res~lts Achieved

Bas~d on review of recent fl~w performance data, as shown in Tables 1 and 2

(attached), for t~e low pressure safety injection check valves (LPSI) and ..

primary coolant system loop check valves (PCS), we believe that these check

valves would be capable of passing their required full flo~ rate if needed.

All rec~ntly recorded flow rates, for both the LPSl and PC~ loop check ~alves,

were within the Q0-88 atceptance range of 1200 to 1800 gp~. Flow rates for

the LSPI check valves obtained in Q0-88 are considered high enough to provide

~n adequat~ level of confidence that the LPSI check valves would be capable of*

passing the 1600 gpm required full flow rate if needed.

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In regard to the PCS loop check valves, it has been determined that th~ fully

open disk position would be achieved at a flow rate 6f about 1900 tb 2100 gpm.

Although Section XI discusses valve testing in terms of full flow testing,

Generic Letter 89-04, ... Guidance on Developing Acceptable Inservice Testing

Programs", allows full valve stroke testing i~ situations where full flo~

. teiting is impractical.

We believe that flow rates achieved in Q0-88 are

. suffi~ient to provide an 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 a~d PCS loop chack val~es a~e included in the plarit preventative

maintenance program.

T.he resu.lts of th~ disassembly and inspections performed

.to date do not identify any concerns with the ability of the PCS loop check

.

valves to pass flow.

Overall, we believ~ that the currertt part strcike testing

of the LPSI ~nd PCS loop check valves along with* their inclusi~n in a

disassembly and inspection p~ogram provides an adequate level of ~onfidence in

the operational readiness of these check valves.

~

Ad~itionally, the PCS loop chetk valves are*the same make and model *as th~

Safety Injection Tank (SIT) check valves (CK-ES3102, CK-ES3117, CK-fS3132, and

Ck-ES3147).

Both the PCS 16op and SIT check valves are 12 inch swing ~heck

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 contludes

that the current disassembly and inspection provides an ade~uate level of

confidence in the operational readiness of the .SIT check valves. Since the

PCS lciop check valves are part strdke tested via Q0-88, and are included in

• .th~ 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 operati9nal readiness of

the SIT check valves. alsb exists for the PCS theck ~alves.

Therefor~ no

additional immediate actions are required.

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• Corrective Actions *to be Taken to Avoid Further Non comp 1 i ance -

1.

Q0-88 will be revised to ac~omplish full flow testing for the LPSI check

valves at greater than 1600 gpm each. This revision to QO-B8 will be :*

complete~ prior to the Palisades 1993 Refueling Outage durin~ when the.

testing will be performed.

3

2.

During the Palisades 1993 Refueling Outage; we will *attempt to verify full

stroke operation of the PCS loop check valves using non-intrusive

instrumentation during Performance of Q0-88.

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3.

If during performan~e of Q0-88 the results are inconclu~ive, a relief

request will be submitted for disassembly and inspection i~ accordance

with NRC .Generic Letter 89-04,"Guidance on Developing Acceptable Inservice

Testing Programs," and further evaluation of full stroke testing of the

PCS loop check valves will be completed to deter~in~ the best long term

resol ut hm. *

4.

A reverification of the required full flow rate~ specifi~d in* EGAD-EP~Ol

will be -conducted to:

a.

Ensure that all check valves *req~iring full flow testing a~e included*

in the valve testing program;

• b. * Ensure that the correct required fl.Ill flow rate and basis are listed

• for each check valve in the valve testing. progra~, and

c.- ,Ensure that all t~st procedures that take credit for full flow testing

~state the cor~ect flow rates as acceptance. crtteria~

Date When Full Compliance Will *be Achieved

All required full flow or stroke testing of the LPSI and PCS* loop check valves

will be attempted during the Palisades 1993 Refueling Outage (scheduled to .

begin in June 1993}. Since the testing of thes~ check ~alves 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 n_eeded for

full compliance will be completed by.July 15, 1993;

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1

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Ck-3101

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U.its

F.-.l307A

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T~'-

1

.~20, 1~7

• 2

F.O 10, 1987

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.)JI 19 I 1 ~7

1600

4

No¥ 06, t 987

1800

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Nov07, 1~

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TABLE 1

Primary Coolant Loop Cbeck V~lve

Flow Test Results .

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Cl<-31 lb

CK-3131. *

CJ(-3146

Fl-0109A

Fl-Ol1 I A

F~14A

1400

1400

1400

1~

1~

1~

1~

1600

1400

-

4

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6. AU9 31, 1988

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7

°'t21,1'88

• 1490

1480

14'°

14'°

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Ftb04, 1989

1SS>

. 1400

1400

1300

~

Ftb09, 1~

10

No* 09, 1. 999

1340

13SJ

135)

1260

11 . ~

10, 19'0

1400

1§)

1~

1300

12

F'.O '7. 1991

1220

1220

14SO

t.400

13

tw30, 1992

1400

1400

1~

-1300

-

• This table is taken from the !ST data base. *Partial tests wer~

performed on these dates for other valves.

No data was taken for

the subject valves on these dates ..

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TABLE 2

• Low Pressure Safety .Injection Check Valves

Flow Test Results

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Parameter No. *

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Name

1

,ldf1 :o. 1967

2

Fttb 10. 1987

.,

"'

Jul 19, 1987

4

~

06. 1987

1750

1600

5

,.~ 07, 1987

6

Aue) 31. 1988

1-00

.8

Feb 04. 1989

1550

9

F~ 09. 1989

J(I

.Nov 09. 1989

1340

1400

12

Feb 17. 1991

1220

13

Mer 30. 1'm

1400

4

6

F1~~114

Fl~J~144

1400

I.JOO

1~00

• • 1:so

1:so

.1750

1600

1-00

. 1490

1490

1400

1400

1300

1350

1350

1260

1350

1350

1220 ..

1-*>0

1350

1300

5

• This table is taken from the !ST data base.

Partial tests were

performed on these dates for other valves.

No data was taken for

the subject valves on these dates.

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