ML18064A485

LER 94-018-00: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.W/941122 Ltr

ML18064A485
Person / Time
Site:	Palisades
Issue date:	11/22/1994
From:	Gire P, Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-94-018, LER-94-18, NUDOCS 9412020150
Download: ML18064A485 (6)

Text

consumers Power KurtM. Haas Plant Safety and Licensing Director POWERiNii MICHlliAN"5 l'IUllilUSS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 November 22, 1994 Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT LICENSEE EVENT REPORT 94-018 - FAILURE TO PROPERLY IMPLEMENT TECHNICAL SPECIFICATION 4.7.1.C, EMERGENCY DIESEL GENERATORS REFUELING OUTAGE INSPECTIONS Licensee Event Report (LER)94-018 is.attached. This event is reportable to the NRC per 10CFR50.73(a)(2)(i)(B), as a condition prohibited by Palisades.

Technical Specifications. *

SUMMARY

OF COMMITMENTS This LER contains five commitments summarized below.

1. *Complete a formal evaluation of the diesel ~enerator manufacturer's recommended inspections. The recommendations will be implemented or justification will be provided which describes why implementation is not appropriate. This action will determine the scope of engine inspections to be completed in the 1995 Refueling Outage. *

2. Complete a revision to RM-63 and its basis document, "Diesel Generator Inspection," to incorporate the necessary changes that result from Action I above.

3. Continue the present effort of evaluating and optimizing preventive maintenance practices for the critical risk significant systems, structures, and components identified during Maintenance Rule, 10CFR50.65, scoping. The.product of this action will b~ maintenance basis documents that contain a documented rationale for the resultant preventive maintenance practices. The development of the maintenance basis documents will include an evaluation of manufacturer recommendations contained in existing equipment files.

9412020150 941122 PDR ADOCK 05000255 PDR s '"'~U A CM5 ENERGY COMPANY

4.

• Revise Palisades Administrative Procedure, 9.45, " Vendor Manual Control", to clarify the process for dispositioning manufacturer's recommended maintenance and inspections. The process shall include a

• formal approval of all exceptions to manufacturer's recommen~ations.

5. Complete the inspections deemed necessary for both EDGs during the 1995 Refueling Outage to maximize component reliability, and also to determine the cause for the slightly reduced maximum output for EOG 1-1. Revise RM-63 and its basis document based on the findings of these inspections.

Kurt M. Haas Plant Safety and Licensing Director CC Administrator, Region Ill, USNRC NRC Resident Inspector - Palisades Attachment

NRC Form 366 U.S. NUCLEAR REGULATORY COMMISSION (8-83) APPROVED OMB NO. 3160-0104 EXPIRES: Bi31 /86

• LICENSEE EVENT REPORT (LERI FACILITY NAME (1 l DOCKET NUMBER (2) PAGE 131 Pcilisades p'1ant 0 6 0 0 0 2 6 6 OF 0 4 TITLE 141 FAILURE TO PROPERLY IMPLEMENT TECHNICAL SPECIFICATION 4.7. 1.C, EMERGENCY DIESEL GENERATORS REFUELING OUTAGE INSPECTIONS EVENT DATE (6) REPORT DATE (8) OTHER FACILITIES INVOLVED (81 REVISION FACILITY NAMES MONTH DAY YEAR YEAR NUMBER MONTH DAY YEAR N/A 0 6 0 0 0 0 2 6 9 4 9 4 0 1 8 0 0 9 4 N/A 0 6 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR I: (Check OM 0/'"""9of1M following} (11)

OPERATING Nt-.,.....2-0-.4-02-lb-l------------........,r--20-.4-0-61-cl------------.--ir--60-.7-3-(1-ll2-Jl-ivl-.-.--------r--..-7-3.~i-1(b-l-------------1 MODE (8)

POWER 20.40611)(1)(i) 60.36(c)(1) 60.7311)(2JM 73.711cl LEVEL 20.40611111 Jliil 60.38(cJ12l 60.731a)(2)(viil OTHER (Specify in Abatrect 20.40611)(1 )(iii) x 60.7311)(2)(i) 60.7311)(2)(viiil1Al below and in Text, 20.4061*111 )fly) 60.73(eJl2lliil 60.7311)(2J(viii)(BJ NRC Form 388AJ 20.406(1)(1 JM 60.731a)(2)(iiil 60.7311)(2)(x)

LICENSEE CONTACT FOR THIS LER (12)

NAME. TELEPHONE NUMBER AREA CODE PAUL J GIRE 6 6 7 6 4 8 9 MANUFAC* REPORTABLE MANUFAC* REPORTABLE CAUSE SYSTEM COMPONENT TUR ER TO NPRDS CAUSE SYSTEM COMPONENT TUR ER TO NPRDS SUPPLEMENTAL REPORT EXPECTED 1141 MONTH DAY YEAR EXPECTED SUBMISSION YES Uf yes, complete EXPECTED SUBMISSION DATEJ . DATE 116)

ABSTRACT (limit to 1400 _.:es, i.e., epproximate/y fifteen .U.g/e--i:e typewritten lines) 116)

On October 26, 1994, plant personnel identified a failure to fully implement a Plant Technical Specification requirement. The requirement is to inspect each diesel generator in accordance with procedures prepared in conjunction with the manufacturer's recommendations. In 1982, the manufacturer provided a new version of inspection recommendations created solely for standby engine service. The new recommendations included major engine tear down inspections every 12 years. Plant engineering determined that this frequency was excessive, but this determination was not sufficiently documented.

• The cause for this event was a failure to maintain an adequate Technical Specification Basis Document to provide a properly documented and approved exception to published manufacturer's recommendations.

Corrective actions for this event include; completing a formal evaluation of the diesel generator manufacturer's recommended inspections, continuing the present effort of evaluating and optimizing preventive maintenance practices for critical risk significant systems, structures, and components within the scope of the Maintenance Rule, and revising plant administrative

• procedures to clarify the process for dispositioning manufacturer's recommended inspections.

NRC Form 388A U.S. NUCLEAR REGULATORY COMMISSION 18*831 APPROVED OMB NO. 3.160-0104 EXPIRES: 8/31 /86 LICENSEE EVENT REPORT (LERI TEXT CONTINUATION FACILITY NAME 111 DOCKET NUMBER 121 LER NUMBER 131 PAGE 141 SEQUENTIAL REVISION YEAR NUMBER NUMBER Palisades Plant 0500025694-o 8 0 2 OF 0 4 EVENT DESCRIPTION On October 26, 1994, while the plant was operating at 100% power, plant personnel identified a failure to fully implement a Plant Technical Specification requirement. The requirement in section 4.7.1.c. is:

"Each diesel generator shall be subjected to an inspection, in accordance with procedures prepared in conjunction with the manufacturer's r.ecommendations for. this class of standby service, at least once per refueling cycle during plant shutdown. The licensee shall utilize his best efforts to conduct additional major diesel generator inspections and overhauls during shutdown periods."

This Technical Specification is implemented by Palisades Technical Specification Surveillance Procedure RM-63, "Diesel Generator Inspection", and its basis document, created in 1980. In 1982, the manufacturer provided a new version of inspect.ion recommendations, Ml-11272, created solely for standby engine service. The new recommendations included major engine tear down inspections at every 18,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of run time or every 12 years, whichever comes first .

. This major tear down inspection was determined by plant engineering to not be necessary at an interval of every 12 years. However, this determination was not sufficiently documented in the basis document and the manufacturer's written concurrence with the change was never obtained.

Thus, it has .been determined that the intent of the Technical Specification requirement was not

.fully implemented.

This event is reportable in accordance with 10CFR50.73(a)(2)(i)(B) as a condition prohibited by.

Palisades Technical Specifications.

ANALYSIS OF THE EVENT The EDGs are operable and have been recently tested to.ensure that they are capable of providing the analyzed peak design basis electrical loads. Based on the results of monthly testing, and the recent peak load tests, the failure to perform the recommended inspections has not resulted in significant engine performance degradation. The present total output of EOG 1-1, at the full fuel position, is slightly less than the pre-operational test res1...1lts from 1971. Thus, it is possible that the slightly reduced engine output is a result of some component degradation, that could have been recognized and corrected during an engine tear down inspection. However, any increased engine output that could have re.suited from the repairs, would only have provided additional margin. The present total output for EOG 1-2, at the full fuel position, is very comparable with the 1971 test results. Thus, the failure to perform the recommended inspections does not presently appear to have affected EOG 1-2 performance.

NRC Form 388A U.S. NUCLEAR REGULATORY COMMISSION 19-83) APPROVED OMB NO. 3160-0104 EXPIRES: 8/31186 LICENSEE EvENT REPORT (LERI TEXT CONTINUATION FACILITY NAME 111 DOCKET NUMBER 121 LEA NUMBER 131 PAGE 141 SEQUENTIAL REVISION YEAR NUMBER NUMBER Palisades Plant 0500025594-0 8 0 3 OF 0 4 A formal review of the manufacturer's recommendations, with a manufacturer technical

• representative, is planned for both EDGs. The results of this review will determine the scope of inspections for both EDGs during the 1995 Refueling Outage .. An inspection was completed on one cylinder's power set on EOG 1-1 in 1988 to determine the general condition of a representative power set ( cylinder, cylinder liner, piston, connecting rod, etc.). The inspected components were in excellent condition, due mainly to the low operating times they had incurred ..

CAUSE OF THE EVENT The cause for this event was a failure to update the appropriate Technical Specification Basis Document to provide a properly documented and approved exception to the published manufacturer's recommendations. Technical Specification Surveillance Procedure RM-63, and its basis document, provide the control and implementation of the required inspection. The manufacturer had provided the new inspection requirements for standby engines in 1982, however the basis document was never changed to include an evaluation of the new requirements.

A contributor to this event was an engineering evaluation contained in the original RM-63 basis document. The basis document was created in 1980, and because 'of the low operating time for the diesel generators, and no specific guidelines at that time for standby engines, it was unclear what inspections were necessary. The basis document stated that the maintenance engineer would review the maintenance and operating history for each EOG, prior to the start of an outage, and determine the appropriate maintenance and inspections. Thus, this somewhat informal evaluation process appeared to provide an adequate overview, and no changes were made to this process when the new standby engine inspection recommendations were obtained.

Another contributor to this event is the lack of an administrative process for evaluating and documenting exceptions to any manufacturer's recommendations. The EDGs are the only Palisades components that have Technical Specification requirements for periodic tear downs. -

However, there are numerous manufacturer recommendations for components with no specific Technical Specifications reference. The Palisades administrative procedure for control of vendor manuals did not exist in the early 1980s, and also presently does not provide adequate direction for dispositioning of manufacturer's recommendations.

CORRECTIVE ACTIONS Proposed corrective actions for this event include;

1. Complete a formal evaluation of the diesel generator manufacturer's recommended inspections. The recommendations will be implemented or justification will be provided which describes why implementation is not appropriate. This action will determine the scope of

. engine inspections to be completed in the 1995 Refueling Outage.

"" NRC Form 366A U.S. NUCLEAR REGULATORY COMMISSION 19-B31 APPROVED OMB NO. 3150-0104

• EXPIRES: B/31/85 LICENSEE EVENT REPORT (LERI TEXT CONTINUATION FACILITY NAME 11 I DOCKET NUMBER 121 LER NUMBER 131 PAGE 141

• SEQUENTIAL REVISION.

YEAR .NUMBER NUMBER Palisades Plant 0500025594-0 8 0 4 OF 0 4

2. Complete a revision to RM-63 and its basis document, "Diesel Generator Inspections," to incorporate the necessary changes that result from Action 1 above.

3. Continue the present effort of evaluating and optimizing preventive maintenance practices for the critical risk significant systems, structures, and components identified during Maintenance Rule, 10CFR50.65, scoping. The product of this action will be maintenance basis documents that contain a documented rationale for the resultant preventive maintenance practices. The development of the maintenance basis documents will include an evaluation pf manufacturer recommendations contained in existing equipment files.

4. Revise Palisades Administrative Procedure, 9.45, " Vendor Manual Control," to clarify the process for dispositioning manufacturer's recommended maintenance and inspections; The process shall include a formal approval of all exceptions to manufacturer's recommendations.

5. Complete the inspections deemed necessary for both EDGs during the 1995 Refueling Outage to maximize component reliability, and also to determine the cause for the slightly reduced maximum output for EOG 1-1. Revise RM-63 and its basis document based on the findings of

~hese inspections.