ML18065A458

LER 96-001-00:on 960103,failed to Test Duplicate Equipment. Caused by STS No Longer Containing Requirement for cross- Train Testing of Duplicate Components.Will Submit Request to Delete Subj Requirements from TS.W/960131 Ltr

ML18065A458
Person / Time
Site:	Palisades
Issue date:	01/31/1996
From:	Smedley R, Vincent R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-96-001, LER-96-1, NUDOCS 9602060137
Download: ML18065A458 (5)

Text

consumers*

Power POWERiNii lllllCHlliAN"S PROGRESS

. Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 January 31, 1996 US Nuclear Regulatory Commission Document Control De.sk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT LICENSEE EVENT REPORT 96-001 - FAILURE TO TEST DUPLICATE EQUIPMENT Licensee Event Report (LER)96-001 is attached. This event is reportable to the NRG in accordance with 10CFR50.73(a)(2)(i)(B) as an operation or condition prohibited by the Plant's Technical Specifications.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Richard W Smedley

.Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRG Resident Inspector - Palisades Attachment 9602060137 960131 PDR ADOCK 05000255 S PDR

- - .._,. \ \J \..,.C' A CMS' EJVeRGY' COMPANY

ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 Licensee Event Report 96-001

.Failure to Test Duplicate Equipment

NRC Form 366 >

' I*

U.S. NUCLEAR REGULATORY COMMISSION

. (9-B3) APPROVED OMB NO. 3150-0104 EXPIRES: B/31 /B5 LICENSEE EVENT REPORT (LERI FACILITY NAME (1) DOCICET NUMBER 121 PAGE 13)

Palisades Plant o I s I o I o I o I I s I s ., I 2 OF 0 13 TITLE 141 LICENSEE EVENT REPORT 96-001 - FAILURE TO TEST DUPLICATE EQUIPMENT EVENT DATE 151 LER NUMBER (6) REPORT DATE 161 OTHER FACILITIES INVOLVED (B)

MONTH DAY YEAR YEAR I I S_EOUENTIAL NUMBER I REVISION NUMBER MONTH DAY YEAR FACILITY NAMES I I I I I I 0 , 0 3 9 6 9 6 - 0 0 , - 0 0 0 , , 3 9 6 NIA o 5 o o o I I I I I I I I I N/A ol5lololol I THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR I: (Check one or more of the following} 111)

OPERATING MODE 19) N 20.402(b)

-- 20.405°

- 50. 731all2lliv)

-- 73.71(b)

.llllllE POWER 20.405(a)( 1)(I) 50.36(cll1l 50. 73(a)(2)(v) 73.71° I I -

1--

LEVEL 20.405(a)( 1 )(ii) 50.36(c)(2) 50. 73(a)(2)(vii) OTHER (Specify in_ Abstract 20.405(a)( 1 )(iii) 20.405(a)( 1 )(iv) 20.405(a)( 1)(v)

- x 50. 73(a)(2)(1)

50. 731all2llii)

50. 73(a)(2)(iii) 1--

50. 73(a)(2)(viii)(A)

50. 731a)(2)(viii)(B) 50.73(a)(2llxl below and in Text.

NRC Form 366A)

LICENSEE CONTACT FOR THIS LER 112)

NAME TELEPHONE NUMBER Robert A Vincent, Licensing Supervisor COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT 113) sARr,cr~ I 7 -, 6 1 4 1 - 1 a 1.9 1 , 1 3

""'"'~ 11111 MANUFAC- MANUFAC- REPORTABLE -

CAUSE SYSTEM COMPONENT TURER TO NPRDS CAUSE SYSTEM COMPONENT TURER TO NPRDS I I I I I I I I I I I I I I I I I I I I I .I I I I I I I 1* *.

SUPPLEMENTAL REPORT EXPECTED (14)

!***************************** MONTH DAY YEAR EXPECTED

- - , YES (/f yes, complete EXPECTED SUBMISSION DATEl ~NO SUBMISSION DATE 11Sl I I I ABSTRACT (Umit to 1400 spaces, i.e., approximately fineen singltt-space typewritten lines) ( 16)

On January 3, 1996, at 2000, with the plant operating at 100% power, the High Pressure Air system supporting oile train of Engineered Safeguards equipment was declared inoperable along with' its associated Containment Sump outlet valve and Safety Injection and Refueling Water Tank (SIRWT) outlet valve. A 1-1/2" air header blowdownvalve (MV-CA522) was partially open and could not be closed. As a result, the air system pressure boundary was transferred to a test rig which had been -

attached down~tream of MV-CA522. The test rig did withstand full air system pressure without failure.

This test rig was not acceptable for continued operation, however, because it did not meet FSAR design criteria for the air system and it was rated at less than air system operating pressure.

With one train inoperable, Technical Specification (TS) 3.3.2 f requires, "Prior to initiating repairs, all valves and interlocks in the system that provide the. duplicate function shall be tested to demonstrate operability." Testing the alternate train Containment Sump and SIRWT outlet valves prior to initiating repairs was imprudent and potentially detrimental to safety, however, because the testing itself would have briefly rendered inoperable the entire redundant train of ECCS. These valves are not normally permitted to be stroked when the reactor is critical. The valves wer~ known to be operable based on successful previous surveillance testing and absence of known equipment problems. The repairs were performed, therefore, without testing the containment sump and SIRWT outlet valves in the redundant train. This was a violation of TS 3.3.2 f.

NRC Form 366A - U.S. NUCLEAR REGULATORY COMMISSION 19-831 . APPROVED OMB NO. 3150-0104 EXPIRES: 8/31/85 LICENSEE EVENT REPORT (LERI TEXT CONilNUATION FACILITY NAME I 11 DOCKET. NUMBER 121 LER NUMBER 131 PAGE 141 SEQUENTIAL REVISION YEAR NUMBER NUMBER Palisades Plant*.

0 5 0 0 0 2 5 5 9 6 0 0 1 Q Q Q .2 OF Q 3 EVENT DESCRIPTION On January 3, 1996, during a preventive maintenance activity, a manual valve (MV-CA522) failed in the Engineered Safeguards High Pressure Air System serving the East Engineered Safeguards Room.

This system provides air to several valves which must operate to support the ECCS safety injection function in both the injection and the recirculation modes. As part of the maintenance activity, a test rig was connected to a header blowdown connection and the. manual.isolation valve (MV-CA522) was.

opened. When the manual valve failed in the open position, the test rig became the pressure boundary for the air system. Although the test rig did withstand air system pressure without failure, it was not acceptable to continue long term operation in this configuration: The test rig could not be approved as a modification under 10CFR50.59 be6ause it was not rated for the air system operating*

pressure, and it did not meet FSAR design requirements for the air system. The air system header had to be depressurized in order to remove the test rig and cap the test connection downstream of the failed valve. Since depressurizing the air header rendered the containment sump outlet valve (CV-3057) and the Safety Injection and Refueling Water Tank (SIRWT) 9utlet valve (CV-3029) inoperable, the TS 3.3.2 f requirement to test the equivalent valves in the redundant train became applicable.

Testing the alternate train valves was_ imprudent and potentially detrimental to safety, however, because it would have brieflyrendered inoperable the entire redundant train of ECCS. Stroking the*

containment sump and SIRWT outlet valves is not normally permitted during plant operation. The valves were known to be operable based on previous successful surveillance testing and the absence

. of known equipment problems. After notifying the Senior Resident Inspector, the East Engineered Safeguards Room high pres_sure air header was isolated and depressurized, and the test connection was capped w_ithout testing of the duplicate valves .in the redundant train.

CAUSE OF THE EVENT.

The Palisades Technical Specifications are custom TS which predate the Standard Technical Specifications (STS). STS no longer contain a r~quirement for cross-train testing of duplicate components to demonstrate operability. While preparations are being made to resolve this and many other TS issues by converting the Palisades TS to STS, this change request has not yet been submitted.

ANALYSIS OF THE EVENT Technical Specification 3.3.2 f states, in part, "Prior to initiating repairs, all valves and interlocks in the system that provide the duplicate function shall be tested to demonstrate operability." This requirement to demonstrate by test that redundant train components are operable is wording from the original Palisades TS. It has since been recognized that cross-train testing in situations such as this is not warranted, and that operability of duplicate or redundant components can tie verified through means other than actual test. .This position was documented in an internal NRC memo dated April 10, 1992

NRC Form 366A ~ U.S. NUCLEAR REGULATORY COMMISSION (9-83) APPROVED OMB NO. 3150-0104 EXPIRES: 8/31 /85 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION FACILITY NAME 111 DOCKET NUMBER 121 LER NUMBER 131 PAGE (41 SEQUENTIAL REVISION YEAR NUMBER NUMBER Palisades Plant 0 5 0 0 0 2 5 5 9 6 0 0 , 0 0 Q 3 OF Q 3 from Christopher I. Grimes to Robert A. Capra, et al. The Standard Technical Specifications for Combustion Engineering Pla_nts, NUREG 1432, no longer requires such cross-train testing.

The actual repairs to MV-CA522 could be performed with the plant on line within the LCO action times of TS 3.3.2 f, but the pre-repair stroke testing of the Containment sump and SIRWT outlet valves in the redundant train could not. The plant could have been taken off line and placed in cold shutdown

• before _the repair in order to allow the required testing, but exposing the plant to a cooldown/heatup transient for the sole purpose of stroking redundant train valves is unwarranted. In addition it was undesirable to delay removal of the test rig from the air header for many hours while the plant was shut down and cooled down since the test rig was a potential personnel safety hazard.

Palisades is developing a comprehensive change request to convert our custom Technical Specifications to emulate Standard Technical Specifications for Combustion Engineering Plants, NUREG-1432. This comprehensive change request is scheduled for submittal by April 1, 1996, and

• implementation in 1997. With the conversion to STS, the requirement to demonstrate operability of duplicate equipment by test will be eliminated from the Palisades TS because it has been deleted from the STS. In view of the potential for similar problems,. however, it has been c_oncluded that a separate TS change request to delete this requirement should be submitted now rather than later with the

• comprehensive TS conversion.

The requirements.for cross-train testing do _not present problems only for the air systems, but can result in imprudent actions for~ number of ECCS components. Requirements for cross-train testing appear in several TS in addition to TS 3.3.2 f. Accordingly, the TS change which is being prepared will request removal of cross-train testing requirements from all sections in which they appear except for Section 3.7. Deletion of cross-train testing requirements from Section 3.7 has already been requested in a TS change request submitted on December 27, 1995..

• CORRECTIVE ACTION A request to delete the requirements for cross-train testing from the Palisades TS will be submitted to the NRC. Submittal is anticipated prior to February 9, 1996.

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