ML18065A916
| ML18065A916 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/12/1996 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9609170183 | |
| Download: ML18065A916 (15) | |
Text
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consumers Power POW ERi Nii llllCHlliAN-S l'IUllillBS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 September 12, 1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT Thomas C. Bordine Manager. Licensing REPLY TO NOTICE OF VIOLATION - APPENDIX R FIRE PROTECTION DEFICIENCIES - NRC INSPECTION REPORT 50-255/96004(DRS)
NRC Inspection Report No. 50-255/96004(DRS) dated May 20, 1996, and NRC Notice of Violation letter dated August 13, 1996, documented the results of an inspection that reviewed several 10 CFR Part 50, Appendix R, fire protection deficiencies. The deficiencies had been identified by Palisades Staff as being outside the design basis of the facility. The Notice of Violation identified one violation which was classified as Severity Level Ill. This violation involved the failure to promptly correct significant conditions adverse to quality for Q-listed fire protection systems and equipment.
Consumers Power Company concurs with the-identified violation. provides the Consumers Power Company reply to the Notice of Violation for the one Severity Level Ill violation.
SUMMARY
OF COMMITMENTS This letter contains six new commitments.
- 1.
All motor-operated valves which have been identified susceptible to damage by the failure mechanism identified by Information Notice 92-18 will be modified by the end of the 1998 refueling outage.
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- 2.
The analysis of the effects of a fire on the barriers between Diesel Generator Room 1-1 and the East Air Plenum Room will be completed by 2
November 1, 1996. If the analysis fails to confirm the adequacy of circuit separation for Diesel Generator power and control circuits, appropriate modifications will be prepared. Any modifications determined to be required will be targeted for completion during the 1998 refueling outage. *
- 3.
A modification has been initiated to install fuses for the 125 volt D.C. panels ED-11-1 and ED-21-1 which w_ill provide for proper fuse coordination. This modification will be completed by the end of the 1996 refueling outage.
- 4.
Modifications to provide necessary illumination of panel ED-21-2 in the Cable Spreading Room and the condenser air ejection pump located in the west mezzanine of the Turbine Building will be completed by June 30, 1997.
- 5.
Members of the Plant Management Staff will be given lessons learned training
.prior to the 1996 refueling outage...
- 6.
- "Group Think" training will be given to managers to assure that corrective actions and 'the safety significance of deficiencies are properly addressed.
Training will be completed prior to the 1996 refueling outage.
Thomas C. *Berdine Manager, Licensing CC Adminis,trator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment
CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this REPLY TO NOTICE OF VIOLATION
- APPENDIX R DEFICIENCIES - NRC INSPECTION REPORT 50-255/96004(DRS),
are truthful and complete.
By
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Tho~Pcimisano Plant General Manager Sworn and subscribed to before me this /cJ ~ day of~
1996.
~Y'{\\~~
Alora M. Davis, Notary Public Berrien County, Michigan (Acting in Van Buren County, Michigan)
My commission expires August 26, 1999
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. ATTACHMENT 1 CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT No.
50-255/96004(DRS) 11 Pages
ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION BACKGROUND During June 1994, in response to Consumers Power company audits and 1994 Diagnostic Evaluation Team (DET) activities at Palisades, the Appendix R Enhancement Program was initiated to review the adequacy of safe shutdown issues relating to fire protection. Reviews were initiated in late summer 1994 and preemptive fire tours were instituted at that time because weaknesses were suspected in the Appendix R Program. The Appendix R Enhancement Program reviews were planned to
- be completed by June 1996 and associated modifications were expected to be completed by the end of the 1998 refueling outage. Because of the Appendix R Enhancement Program, nine Licensee Event Rep~rts (LERs) regarding Appendix R and Fire Protection Program deficiencies have been issued. NRC Inspection
.50-255/96004 reviewed the effectiveness of corrective actions associated with these
.LERs and found one violation.
NRC Notice of Violation letter dated August 13, 1996, identified the one violation. This reply restates information (including actions) that was discussed during the June 21, 1996, Predecisional Enforcement Conference.
VIOLATION 50-255/96004 The licensee failed to promptly correct significant conditions adverse to quality for Q-Listed fire protection systems and equipment, as evidenced by the following examples:
A.
From November 3, 1995, through April 29, 1996, Palisades failed to implement timely and effective corrective actions for previous NRG and licensee identified noncompliances with the requirements of 10 CFR Part 50, Appendix R, in that the facility's alternate shutdown emergency AC power source, Diesel generator 1-1, !.'.Vas not properly isolated from associated circuits. Specifically, the Diesel.
Generator 1-1 potential transformer circuit prif1}ary and secondary fuses were not properly coordinated which could have caused the Joss of automatic and manual voltage control and rendered Diesel Generator 1-1 inoperable. Although this deficiency was identified on November 3, 1995, the licensee failed to provide adequate guidance to the operators which would have enabled them to promptly identify.this condition and to take the necessary actions to recover the diesel generator and mitigate the consequences of this event.
1
B.
From July 28, 1995, through March 27, 1996, Palisades failed to implement timely and effective corrective actions for previous NRG and licensee identified noncompliances with the requirements of 1 O CFR Part 50, Appendix R.
Specifically, procedures did not exist to conduct cold shutdown repairs to restore a low pressure safety injection pump following a fire in the east engineered safeguards room, Fire Area 10, or in the 590' corridor auxiliary building, Fire Area
- 13. The Palisades corrective actions, which were completed on December 1, 1995,.consisted of proceduralizing the necessary repairs to allow local manual operation of the breaker were not adequate to isolate a fire induced fault and to allow local manual operation of a low pressure safety injection pump to permit cold shutdown of the facility.
C.
From February 28, 1992, through April 29, 1996, Palisades failed to implement timely and effective corrective actions for safe shutdol/Vn motor-operated valve circuits, which could have been affected by fire induced hot shorts as described in NRG Information Notice (IN) 92-18, "Potential for Loss of Remote Shutdown Capability During a Control Room Fire.
11 Specifically, in response to this IN, Palisades had performed three different safety evaluations which were not adequate to identify which motor-operated valves were susceptible to damage by this failure mechanism. In addition, since the most recent evaluation completed on December 19, 1995, no specific guidance was provided to the operators to enable them to quickly identify this condition.and take 'appropriate actions to mitigate (he con$equences of this event.
o:
From July 14, 1995, through April 29, 1996, Palisades failed to implement timely and effective corrective actions for previous NRG and licensee identified noncompliances with the requirements of 1 O CFR Part 50, Appendix R.
Specifically, on July 14, 1995, Palisades determined that Emergency Diesel Generator 1-2power and control circuits were not adequately separated.
Palisades corrective action for this condition, an analysis to determine an effective rating for the barrier between the redundant trains, EA-FPP-95-047, "Analysis of the Effects of a. Fire on the Barriers Between Diesel Generator Room 1-1 and the East Air Plenum Room, 11 dated November 14, 1995, which concluded the configuration was acceptable, was not adequate, in that:-(1) the* analysis did*
not consider all possible failure modes for an operating diesel or operating modes of the diesel room ventilation system; (2) the analysis did not evaluate the potential impact of degraded or inoperable suppression systems; and (3) the methodology utilized to evaluate the fire severity was not conservative.
E.
From September-2-7, -1995, through April 29, 1996, Palisades failed to implement timely and effective corrective action for the improper setting of the Alternate Shutdown Panel Inverter low voltage cut-off setpoint. Specifically, the safety significance of this setpoint was not recognized; the condition report initiated due 2
F.
to the inverter failure was not comprehensive which resulted in a cursory evaluation of the condition and a failure to recognize the safety significance and reportability of the deficiency; and the adjustment of this setpoint was performed without an engineering evaluation or the use of any setpoint methodology.
From February 2, 1996 through April 29, 1996, Palisades failed to implement timely and effective corrective actions for previous NRG and licensee identified noncompliances with the requirements of 1 O GFR Part 50, Appendix R.
Specifically, the main supply fuses for the 125 Volt D. G. panels, ED-11-1 and ED 21-1, were not properly coordinated with the branch circuit breakers. This condition was identified on February 2, 1996, but effective corrective action had not been taken to correct this deficiency as of April 29, 1996.
G..
From November 14, 1986, through April 29, 1996, Palisades failed to implement timely and effective corrective actions for emergency lighting deficiencies identified by the NRG during an Appendix R inspection completed in Septe_mber 1986, and during a follow-up inspection completed in June 1988. Specifically, as
. of April 29, 1996, adequate emergency lighting had not been provided for the necessary illumination of: (1) Panel ED-21-2 in the cable spreading room and (2) the condenser air ejection pump in the west mezzanine of the turbine building.
CONSUMERS POWER COMPANY REPLY (1)
Consumers Power Company admits the violation existed.
(2)
REASON FOR THE VIOLATION The violation occurred because of the reasons described below:
- 1.
Programmatic Reasons Prior to 1994, management weaknesses resulted in inadequate compliance efforts by not providing sufficient resources to accomplish the.
necessary activities. This also led to poor self-assessments and inadequate maintenance of the Appendix R Program.
The original Appendix R analysis was not of sufficient detail to fully verify Appendix R requirements. Because management personnel were satisfied with the hourly fire* tours as compensatory measures, more permanent measures (e.g., procedure changes) were not made while modifications were pending. Additionally, because the "mind set" was in 3
- 2.
place that fire tours were sufficient, permanent corrective actions were not scheduled appropriately in view of the potential safety significance.
Specific Reasons for Each Example
- a.
The Diesel Generator 1-1 potential transformer circuit primary and secondary fuses were not properly coordinated which could have caused the loss of automatic and manual voltage control and rendered Diesel Generator 1-1 inoperable. (LER 95-013)
The original Appendix R analysis, which determined the associated circuits for Diesel Generator isolation, was not of sufficient detail to
- fully verify proper fuse coordination. When this lack of coordination was discovered as part of the Appendix R Enhancement Program, plant management was satisfied that the hourly fire tours provided adequate compensatory measures. The operators were provided with training, but more permanent measures (e.g., procedure changes) were then not considered necessary while modifications were pending. Additionally,
- because of the "mind set" that fire t0urs were sufficient, the fuse..
replacement was not accelerated appropriately in view of the potential safety significance..
- b.
- Procedures did not exist to conduct cold shutdowf! repairs to restore a low pressure safety injection pump following a fire in the east engineered safeguards room, Fire Area 10, or in the 590' corridor auxiliary building, Fire.Area 13. (LER 95-009)
Corrective actions were completed to resolve the noncompliance issue to restore the low pressure safety injection pump to an operable condition following a fire. However, both the technical work and, the supervisory review were inadequate to recognize that the revised procedure did not accomplish the necessary repairs to isolate-a fire-induced fault and allow local manual -
operation of the low pressure safety injection pump.
- c.
In response to (IN) 92-18, Palisades had performed three different safety evaluations which were not.adequate to identify which motor-operated valves were susceptible to damage by this failure mechanism. (LER 95-015).
Prior to 1994, delays in analyzing hot shorts in the operation of
- motor-operated valves (MOVs) were primarily the result of the 4
- d.
perception that this was a very low probability issue. After 1994, iterative analyses were developed based on incomplete evolving information which delayed the ultimate resolution. Due to the "mind set" in place that fire tours were sufficient, no specific guidance was provided to operators to enable them to quickly
. identify this condition and take appropriate actions to mitigate the consequences of this event.
Palisades determined that Emergency Diesel Generator 1-2 power and control circuits were not adequately separated. (LER 95-004)
Modifications completed in the early 1980's, which were designed to provide Appendix R circuit separation, were inadequately.
evaluated and, therefore, did not properly address the issue. The analysis, which determined the barrier configuration between the redundant trains was acceptable for a three hour fire rating, was not of sufficient detail.
- e.
From September 27, 1995, through April 29, 1996, Palisades failed to implement timely and effective corrective action for the improper setting of the Alternate Shutdown Panel Inverter low voltage cut-off setpoint. Specifically, the safety significance of this setpoint was not recqgnized; the condition report initiated due to the inverter failure was not comprehensive, which resulted in a cursory evaluation of the condition and a failure to recognize the safety significance and reportability of the deficiency; and the adjustment of this setpoint was performed without an engineering. evaluation or the use of any setpoint methodology.
During initial installation of the alternate shutdown panel, acceptance testing did not verify or test operability of t~e panel
- when powered from batteries alone. Subsequent surveillance testing had also been inadequate. The modification process also neglected.to establish periodic* surveillance requirements for this aspect of equipment operation.
An opportunity was missed by plant personnel to recognize this situation when a General Electric Service Information Letter, issued in June 1985, identified this particular issue on a similar power: supply from another manufacturer.
When the regular surveillance test was completed in September 1995, plant personnel failed to recognize, during the corrective 5
action evaluation, the safety significance of the low voltage cut-off setpoint for past operability of the panel. Upon replacement of the failed board, the low voltage cutoff setpoint was reset to assure proper operation; however the new setpoint was not evaluated in accordance with the proper administrative requirements.
- f.
The main supply fuses for the 125 Volt D. C. panels, ED-11-1 and ED 21-1, were not properly coordinated with the branch circuit breakers. (LER 96-005)
- g.
A modification which was completed in 1986 did not properly address the Appendix R fuse coordination issue between the main supply fuses and the branch circuit breakers. Additionally, effective corrective action had not been completed to resolve this deficiency in a timely manner.
Adequate emergency lighting had not been provided for the necessary illumination of: (1) Panel ED-21-2 in the cable spreading room and (2) the condenser air ejection pump in the west mezzanine of the turbine building. (LER 96-007)
Evaluations and previous corrective actions completed to address
_Appendix R issues relating to emergency lighting were inadequate and ineffective.
(3)
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The following corrective actions have been taken:
- 1.
Programmatic Actions.
The Appendix R Enhancement Pr9gram was started in 1994 because the
_existing program was determined to be inadequate and additional work was warranted. This program is systematically reviewing and upgrading plant compliance strategies for Appendix R.
In light of the problems found in some corrective actions, a review of the adequacy of all open corrective actions was performed. From this review,
__ additional compensatory measures and additional accelerated corrective actions were taken. This review also included an assessment of technical reviews previously performed to determine if they were adequate.
6
The plant modification process was revised to better control modifications and strengthen the fire protection/ Appendix R review criteria. For example, a detailed checklist has been created to provide better direction to the modification engineer when considering modifications that may affect fire protection and safe shutdown.
The corrective action process has been reviewed and procedural changes have been completed to ensure that more comprehensive evaluations are performed when the type and scope of corrective action is determined.
- 2.
Specific Causes of Violations - Corrective Actions
- a.
The Diesel Generator 1-1 potential transformer circuit primary and.
secondary fuses were not properly coordinated which could have caused the loss of automatic and manual voltage control and rendered Diesel Generator 1-1 inoperable.
Corrective actions included providing adequate guidance to the operators.* This guidance would enable them to promptly identify this condition and take the.necessary actions to recover the diesel generator and mitigate the consequences of this event.
The modification to provide proper fuse coordination and provide isolation from associated circuits was accelerated and completed on June 3, 1996.
- b.
- Procedures did not exist to conduct cold shutdown repairs to
.c.
- restore a low pressure safety injection pump following a fire in.the east engineered safeguards room, Fire Area 10, or in the 590' corridor auxiliary building, Fire Area 13.
Correetive actions included verifying hourly fire tours were in place in the appropriate. areas, and the proper fuses were* placed into the stock system which will make the fuses readily available if needed.
Procedural guidance has been provided to operators to direct them to make repairs to isolate a fire-induced fault and to allow local manual operation of a low pressure safety injection pump.
-In response-to (IN) 92-18, Palisades had performed thtee different safety evaluations which were not adequate to identify which motor-operated valves.were susceptible to damage by this failure mechanism.
7
Corrective actions included verification that the preemptive fire tours were in place at the appropriate locations, and issuance of guidance to operators to enable them to identify this condition and take appropriate actions to mitigate the consequences of this event.
In response to (IN) 92-18 "Potential for Loss of Remote Shutdown Capability During a Control Room Fire," an engineering analysis has been completed which adequately identifies which motor-operated valves are susceptible to damage by this failure mechanism. This has resulted in four of the val_ves being scheduled to be modified in 1996 to correct this condition and fifteen additional valves are be.ing considered for modification during the 1996 refueling outage, if practical. All remaining valves will be modified in the next scheduled refueling outage, currently.
planned for 1998.
- d.
Palisades determined that Emergency Diesel Generator 1-2 power and control circuits were not adequately separated.
Corrective actions associated with the circuits in the Diesel Generator Air Plenum Room included verification that fire tours were in place in the appropriate areas. The specific analysis (EA-FPP-95-047) "Analysis of the Effects of a Fire on the Barriers Between Diesel Generator Room 1-1 and the East Air Plenum Room," is being revised to more conservatively represent the actual as-built configuration of the barrier and the fire loading.
Specifically the revised analysis includes consideration of possible failure modes for*the operating diesel and Diesel Room ventilation system. The analysis evaluates the potential impact of degraqed or inoperable suppression systems arid the methodology utilized to*
evaluate the fire severity is more conservative than the previous revision. We believe that the analysis, when completed, will confirm the adequacy of the as-built configuration to provide circuit -
separation for the power and control circuits of the Diesel
- Generator 1-2 from Diesel Generator 1-1.
The plant modification process was revised to strengthen the fire protection/ Appendix R review criteria; for example, a detailed checklist has been created to provide better direction to the modification engineer when considering modifications that may affect fire protection and safe shutdown.
8
- e.
From September 27, 1995, through April 29, 1996, Palisades failed to implement timely and effective corrective action for the improper setting of the Alternate Shutdown Panel Inverter low voltage cut-off setpoint. Specifically, the safety significance of this setpoint was not recognized; the condition report initiated due to the inverter failure was not comprehensive, which resulted in a cursory evaluation of the condition and a failure to recognize the safety significance and reportability of the deficiency; and the adjustment of this setpoint was performed without an engineering evaluation or the use of any setpoint methodology.
Corrective actions included resetting of the setpoint to the proper value after evaluation of the specific requirements and consultation with the vendor. A surveillance has been established to periodically verify the low voltage cutoff setpoint, and lessons learned training will be provided to selected personnel to reinforce the safety significance of this event and the related reportability requirements. These actions will be completed prior to the 1996 refueling outage.
Industry experience information will now receive a system engineering review as a routine measure to assure the plant is cognizant of developing technical issues.
- f..
The main supply fuses for the 125 Volt D. C. panels, ED-11-1 and ED 21-1, were not properly coordinated with the branch circuit breakers.
Corrective actions included verification that hourly fire tours were in place in the appropriate areas and completion of evaluations to determine if there were other 125 Volt D.C.. coordination issues similar to the condition described above. These evaluations also confirmed the adequacy of the AC coordination design for the
- - panels in question.
A modification was initiated to install fuses which will provide for proper coordination. This modification is scheduled for the 1996 refueling outage.
- g. -
- -Adequate* emergency lighting had not been provided for the
- necessary illumination of" (1) Panel ED-21-2 in the cable spreading room and (2) the condenser air ejection pump in the west mezzanine of the turbine building.
9
(4)
Completed corrective actions included: (1) alerting operations personnel that the questionable lighting conditions exist. (2) A station lighting blackout test has been completed which confirmed the adequacy of most existing emergency lighting, as well as planned corrective actions. Corrective actions include redirecting lamps, adding a third lamp to other lighting units, and adding two new lighting units. These resulting modifications, which provide necessary illumination of panel ED-21-2 in the Cable Spreading Room and the condenser air ejection pump located in the west mezzanine of the Turbine Building, are scheduled to be complete by June 30, 1997.
CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE The following corrective actions are planned to enhance the control of Appendix R Program:
- 1.
All motor-operated valves which have been identified susceptible to
- damage by the failure mechanism identified by *Information Notice 92-18 will be modified by the end of the 1998 refueling outage.
- 2.
The analysis of the effects of a fire on the barriers between Diesel Generator Room 1-1 and the East Air Plenum Room will be completed by November 1, 1996. If the analysis fails to confirm the adequacy of circuit separation for Diesel Generator power and control circuits, appropriate modifications will be prepared. Any modifications determined to be required will be targeted for completion during the 1998 refueling outage.
- 3.
.A modification has been initiated to install fus.es for the 125 volt D.C.
panels ED-11-1 and ED-21.1 which will provide for proper fuse coordination. This modification will be completed by the end of the 1996
-refueling *outage.
- 4.
Modifications to provide n*ecessary illumination of panel ED-21-2 in the Cable Spreading Room and the Condenser Air Ejection Pump located in the west mezzanine of the Turbine Building will be completed by June 30,
- 1997.
- 5.
Members of the Plant Management Staff will be given lessons learned training prior to the 1996 refueling outage.
10
~l.
- 6.
"Group Think" training will be given to managers to assure that corrective actions and the safety significance of deficiencies are properly addressed. Training will be completed prior to the 1996 refueling outage.
(5)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by the end of the 1998 refueling outage.
11