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- I consumers Power POWERINli MICRlliAN'S PRDliRESS PJtisades Nuclear Plant.
27780 Blue Star Memorial Highway, Covert, Ml 49043 I
I May 25, 1994 Nuclear Regulatory Commission
. Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT David W. Rogers Plant Safety and Licensing Director LICENSEE EVENT REPORT 94-011 - PREVIOUSLY UNANALYZED COMBINATION OF EVENTS INDICATES POTENTIAL FOR INABILITY OF A SINGLE SOURCE TO RELIABLY START DIESEL GENERATORS.
Licensee Event Report (LER)94-011 is attached. This condition is reportable to the NRC per 10CFRS0.73(a)(2)(ii)(B) as a condition outside the design basis of the plant.
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David W. Rogers Plant Safety and Licensing Director CC Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment
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NRC Form 388 U.S. NUCLEAR REGULATORY COMMISSION Cl-831 APPROVED !)MB NO. 31~104 EXPIRES: 8/31/86 LICENSEE EVENT REPORT (LERI FACILITY NAME 111 DOCKET NUMBER 121 PAGE 131 Palisades Plant o I s I a* I o I o I 2 I s I s 1IOFIQIJ TITLEl41 PREVIOUSLY UNANALYZED COMBINATION OF EVENTS INDICATES POTENTIAL FOR INABILITY OF A SINGLE SOURCE TO RELIABLY START DIESEL GENERATORS.
EVENT DATE 161 LER NUMBER 161 REPORT DATE 161 OTHER FACILITIES INVOLVED 181 i
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REVISION FACILITY NAMES.
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.60.731*ll2llviii11Bl NRC Form 386AJ 20.4061*111 llvl 60.731oll211iiil 60.731*11211xl LICENSEE CONTACT FOR THIS LER 1121
.. j NAME TELEPHONE NUMBER Richard W. Smedley, Staff Licensing Engineer 6ARIEA1CI°~ I 7 I 6 I 4 I I 8 I 9 I 1 I 3 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE _DESCRIBED IN THIS REPORT 1131 MANUFAC*
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SUPPLEMENTAL REPORT EXPECTED 114)
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DATE 1161 ABSTRACT UJm/tto 1400llPllCOS. ie., epptTJJt/,,.,,to/y fifteen-aingle-spece typewritten linHI 1161 On Aprii 25; 1994, wi_th the plant in cold shutdown,* plant personnel discovered that, in certain circumstances, the ability of the plant's Emergency Diesel Generator's (EDGs) to start within the prescribed time frame could be adversely impacted. When loss of a station battery was considered as a single failure mechanism along with a design basis accident and loss of offsite power the result would be a reliance on only one starting circuit for each EDG.. That circuit is the "A" air start circuit for both diesel generators. The starting time for the "A" air start circuit for EOG 1-2 had previously exceeded the specified starting time. The single failure, a station battery I had not occurred in the past and availability of all starting circuits for both EDGs had not been impacted. However, the effect of the identified condition placed the plant outside its design basis.. The slow air start motor and its regulator have been replaced and tested satisfactorily.
Procedu.res used to control testing of both EDGs have been changed to reflect the information obtained as a result of this discovery.
J' NRC Form 386A
{9-831 FACILITY NAME 111 Palisade's Plant E
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- LICENSEE EVENT REPORT (LERI TExT CONTINUATION DOCKET-NUMBER 121 LEA NUMBER 131 U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3160-0104 EXPIRES: 8/31 /86 PAGE 141 SEQUENTIAL REVISION YEAR NUMBER NUMBER 0500025594-011 0
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On Aprill 25, 1994, with the plant in... cold shutdown, itwas identified that there were a co.mbin~tion of circumstances which, when taken together, could result in a slower than specified start of Emergency Diesel Generators (l;DGs). The combination of events and circumstances which would impact EOG performance. was discovered by plant personnel wtio were addressing an issue raised by the NRC Diagnostic Evaluation Team (DET) staff. The. scenario which could result in a slow start requires the following: An event, such as a loss of coolant accident (LOCA) and resulting loss of offsite power, failure of a station battery, and start time of the "A" motor above 9.5 seconds. When offsite power would be lost, the undervoltage condition would initiate a start of EDGs utilizing both "A" and "B" starting motors. Plant experience as well as testing confirm EOG. starts within the Technical Specification time limit. However, with the loss of a station battery, only the "A" starting motor would be available. The "A" starting motor on EOG 1-2.has recently taken 9.99 seconds to start. Per procedure, a second.attempt using both motors was successfully completed. Though acceptable at the time, the procedure did not-consider the battery loss and resulting reliance on only the "A" motor which had exceeded its start time. The net effect of the condition placed the plant outside its design* basis as described in its FSAR.
Cause of Event
The plant's investigation identified that there was an incomplete understanding of the implications of the undervoltage starting circuit arrangement and the slow start times for the "A" air start motor on EOG 1-2. The possibility for a single f~ilure, in this case a loss of a stati'on battery, placing reliance on the "A" starting circuit of one diesel generator was not recognized.
Analysis of Event
Two starting circuits,. n An and "B" I are utilized for both Palisades Emergency Diesel Generators. If there were an event such as a LOCA, a concurrent loss of offsite power and a failure of either station battery 001 or D02, only the EOG "A" start circuitry capability would remain to start the associated diesel generator. Loss of station battery DO 1, in combination* with the other two
- events, would result in the loss of control power to both starting circuits for Emergency Diesel Generator EOG 1-1. This condition would a!so result in a loss of power to auxiliary relays which provide a start signal to the "B" air start motor for EOG 1-2. Because the "A" air start motor for EOG 1-2 had, at times in the past, exceeded its requirement to start EOG 1-2 within 9.5-seconds, -
the circumstances identified would have resulted in an inability of EOG 1-2 to meet design basis requirements. Because the failure was possible, this condition is reportable per*
10CFR50.73(a)(2)(ii)(B) as outside the plant's design basis.
NRC Form S88A 19-831 FACILITY NAME C11 Palisades Plant
. I Safet\\t lsignjficance I !
DOCKET NUMBER 121 YEAR LER NUMBER 131 SEQUENTIAL "NUMBER REVISION NUMBER
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PAGE 141 Oil OF OIJ A loss of offsite power prompts a start of EOGs utilizing both air start motors. When both are used for a start, performance has met technical specification criteria.* Although the scenario described in this report notes a. potential for exceeding the 10-second start up requirement, the plant has not experienced.a loss of a station batt~ry which would force a reliance on only one circuit.
Correc,ive Actions The following actions have been completed:
The slow starting motor and its regulator were replaced.
Procedu.res used for EOG start testing have been revised so that a slow start using the "A" air start motor will result in declaring the EOG inoperable.
J The following action will be completed:
l A* modification will. be completed during the 1995 refueling outage that will eiimiriate the potential depe~dance on a single* starting circuit capability.
Previous Occurrences
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| 05000255/LER-1994-001, :on 940121,both Trains of Control Room Emergency Heating,Ventilation & Air Conditioning Inoperable. Caused by Screen Plugged W/Ice & Snow.Surveillance Procedure Revised |
- on 940121,both Trains of Control Room Emergency Heating,Ventilation & Air Conditioning Inoperable. Caused by Screen Plugged W/Ice & Snow.Surveillance Procedure Revised
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-002, :on 940126,inadvertent Containment Spray Pump ESF Actuation Occurred During Performance of TS Surveillance Testing.Caused by Inadequate Procedure.Tssp Q0-1 Modified to Warn Operators of CSP Start |
- on 940126,inadvertent Containment Spray Pump ESF Actuation Occurred During Performance of TS Surveillance Testing.Caused by Inadequate Procedure.Tssp Q0-1 Modified to Warn Operators of CSP Start
| | | 05000255/LER-1994-003-01, :on 940209,discovered That Single Active Failure Could Disable Seal Cooling to Ess Pumps & Backup Cooling Supply Not Fully Qualified.Affected Valves Opened to Eliminate Possibility of Single Failure |
- on 940209,discovered That Single Active Failure Could Disable Seal Cooling to Ess Pumps & Backup Cooling Supply Not Fully Qualified.Affected Valves Opened to Eliminate Possibility of Single Failure
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000225/LER-1994-003, :on 940203,position Switches for Containment Air Cooler Svc Inlet & Valves Not Qualified for Submergence. Caused by Master Equipment List Which Did Not Alert User of Existence of Qualification Restrictions |
- on 940203,position Switches for Containment Air Cooler Svc Inlet & Valves Not Qualified for Submergence. Caused by Master Equipment List Which Did Not Alert User of Existence of Qualification Restrictions
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-004, :on 940209,ESS Pump Cooling Failed. Caused by Failure to Recognize That Ess Pumps Dependent on Seal & Bearing Cooling.Revised Plant Operating Procedures So Normal Position for CV-0913 & CV-0950 Open |
- on 940209,ESS Pump Cooling Failed. Caused by Failure to Recognize That Ess Pumps Dependent on Seal & Bearing Cooling.Revised Plant Operating Procedures So Normal Position for CV-0913 & CV-0950 Open
| 10 CFR 50.73(a)(2)(ii)(8) | | 05000255/LER-1994-005, Retracts LER 94-005 Re Lack of Physical Separation Between Redundant Channels of safety-related Instrumentation Circuits.Cable Thought to Be Installed in Trays 3XU-109 & 3XU-11 Not Installed in Subj Trays | Retracts LER 94-005 Re Lack of Physical Separation Between Redundant Channels of safety-related Instrumentation Circuits.Cable Thought to Be Installed in Trays 3XU-109 & 3XU-11 Not Installed in Subj Trays | 10 CFR 50.73(a)(2) | | 05000255/LER-1994-006, :on 940217,plant Shutdown Per TSs Due to Leak on Asme,Section Xi,Class 2 saftey-related Check Valve. Caused by Through Wall Defect on Valve CK-ES3166.Check Valves CK-ES3166 & CK-ES3188 Replaced |
- on 940217,plant Shutdown Per TSs Due to Leak on Asme,Section Xi,Class 2 saftey-related Check Valve. Caused by Through Wall Defect on Valve CK-ES3166.Check Valves CK-ES3166 & CK-ES3188 Replaced
| 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | | 05000255/LER-1994-007, :on 940308,EDG Fuel Oil Transfer Sys Including Storage Tank T-10 & Associated Piping Found Not Tornado Protected.Caused by Design Errors.Barriers Around T-10 Provided |
- on 940308,EDG Fuel Oil Transfer Sys Including Storage Tank T-10 & Associated Piping Found Not Tornado Protected.Caused by Design Errors.Barriers Around T-10 Provided
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-008, :on 940329,30 & 0409,discovered That Some Class 1E Circuits Not Isolated or Separated from non-Class 1E Circuits Due to Lack of Engineering Design Guides.Subj Deviations Corrected W/Exception of CETs |
- on 940329,30 & 0409,discovered That Some Class 1E Circuits Not Isolated or Separated from non-Class 1E Circuits Due to Lack of Engineering Design Guides.Subj Deviations Corrected W/Exception of CETs
| 10 CFR 50.73(a)(2) | | 05000255/LER-1994-009, :on 940407,identified That Condensate Storage Tank & Primary Coolant Sys Makeup Tank Combined Inventory Below TS Limits.Caused by Inadequate Original Plant Design. Applicable Operating Procedures Modified |
- on 940407,identified That Condensate Storage Tank & Primary Coolant Sys Makeup Tank Combined Inventory Below TS Limits.Caused by Inadequate Original Plant Design. Applicable Operating Procedures Modified
| | | 05000255/LER-1994-010, :on 940302,two Hinged Horizontal Panels of Insulation Comprising Convection Barrier Not in Closed Position.Caused by Increase in Temp & Shallowness of Through Wall Gradients |
- on 940302,two Hinged Horizontal Panels of Insulation Comprising Convection Barrier Not in Closed Position.Caused by Increase in Temp & Shallowness of Through Wall Gradients
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.72(b)(3)(ii), Degraded or Unanalyzed Condition | | 05000255/LER-1994-011, :on 940425,discovered That Previously Unanalyzed Combination of Events Could Result in Slower than Specified Start of Edgs.Slow Starting Motor & Regulator Replaced |
- on 940425,discovered That Previously Unanalyzed Combination of Events Could Result in Slower than Specified Start of Edgs.Slow Starting Motor & Regulator Replaced
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-012-01, :on 940427,w/plant in Cold Shutdown,Determined That Internal Ground in Thermal Margin Monitor Caused Nonconformance W/Rps Design Basis.Mod Implemented to Effectively Isolate Grounded Monitor from Pressure Loop |
- on 940427,w/plant in Cold Shutdown,Determined That Internal Ground in Thermal Margin Monitor Caused Nonconformance W/Rps Design Basis.Mod Implemented to Effectively Isolate Grounded Monitor from Pressure Loop
| | | 05000255/LER-1994-012, :on 940427,determined That Internal Ground in Thermal Margin Monitor Causes Nonconformance W/Rps Design Basis.Incorporated RPS Failure Modes & Effects Analysis in Plant DBD |
- on 940427,determined That Internal Ground in Thermal Margin Monitor Causes Nonconformance W/Rps Design Basis.Incorporated RPS Failure Modes & Effects Analysis in Plant DBD
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-013, :on 940427,unsupported RCP Instrument Tubing Identified as Being Outside of Plant Design Basis Due to Lack of Supports.Tubing Supports Installed & Now Conforms to Spec Criteria |
- on 940427,unsupported RCP Instrument Tubing Identified as Being Outside of Plant Design Basis Due to Lack of Supports.Tubing Supports Installed & Now Conforms to Spec Criteria
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-014, :on 940530,identified Potential Block Containment Sump.Caused by Lack of Controls on Use of Material Used to Attach Signs & Labels.Revision to Checklist Will Be Performed |
- on 940530,identified Potential Block Containment Sump.Caused by Lack of Controls on Use of Material Used to Attach Signs & Labels.Revision to Checklist Will Be Performed
| 10 CFR 50.73(a)(2)(v), Loss of Safety Function | | 05000255/LER-1994-015, :on 940601,electrical Cable Revealed to Be Not Environmentally Qualified for Use in Application Due to Installation of Nonenvironmentally Qualified Cable.Jco Initiated as Defined in GL 91-18 |
- on 940601,electrical Cable Revealed to Be Not Environmentally Qualified for Use in Application Due to Installation of Nonenvironmentally Qualified Cable.Jco Initiated as Defined in GL 91-18
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(ii)(8) | | 05000255/LER-1994-016, :on 940824,identified Situation Where Previous Concentrated Boric Acid Tank Concentrations Outside of TS Limits.Caused by Inaccurate Analysis.Boric Sample & Analysis Techniques from PCS & SFP Reviewed |
- on 940824,identified Situation Where Previous Concentrated Boric Acid Tank Concentrations Outside of TS Limits.Caused by Inaccurate Analysis.Boric Sample & Analysis Techniques from PCS & SFP Reviewed
| 10 CFR 50.73(a)(2) | | 05000255/LER-1994-017-01, Forwards Response to NRC RAI Re LER 94-017-01, Edg,Edg 1-1, Degraded Load Carrying Capability-Supplemental Rept | Forwards Response to NRC RAI Re LER 94-017-01, Edg,Edg 1-1, Degraded Load Carrying Capability-Supplemental Rept | | | 05000255/LER-1994-017, :on 940902,EDG 1-1 Degraded Load Carrying Capability Identified.Caused by Inadequate Design Basis, Failure to Effectively Monitor for Engine Performance Degradation & Failure to Control Mods |
- on 940902,EDG 1-1 Degraded Load Carrying Capability Identified.Caused by Inadequate Design Basis, Failure to Effectively Monitor for Engine Performance Degradation & Failure to Control Mods
| 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition | | 05000255/LER-1994-018, :on 941026,failure to Properly Implement TS 4.7.1.C,EDG Refueling Outage Insps Occurred.Caused by Failure to Maintain Adequate TS Basis Documents.Formal Evaluation of Recommended Insps Initiated |
- on 941026,failure to Properly Implement TS 4.7.1.C,EDG Refueling Outage Insps Occurred.Caused by Failure to Maintain Adequate TS Basis Documents.Formal Evaluation of Recommended Insps Initiated
| 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | | 05000255/LER-1994-019, :on 941109,identified Failure to Test Redundant Equipment Per TS 3.3.2.f Prior Ro Removal of Electrical Breakers from Svc for Planned PM Due to Personnel Error. Administrative Procedure 5.14 Revised |
- on 941109,identified Failure to Test Redundant Equipment Per TS 3.3.2.f Prior Ro Removal of Electrical Breakers from Svc for Planned PM Due to Personnel Error. Administrative Procedure 5.14 Revised
| 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | | 05000255/LER-1994-020, :on 941207,inadvertent Actuation of AFW Flow Occurred During Performance of TS Surveillance Testing Because of Failed Electrical Relay.Administrative Procedure 4.02, Control of Equipment Will Be Revised |
- on 941207,inadvertent Actuation of AFW Flow Occurred During Performance of TS Surveillance Testing Because of Failed Electrical Relay.Administrative Procedure 4.02, Control of Equipment Will Be Revised
| 10 CFR 50.73(a)(2)(iv), System Actuation |
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