05000255/LER-1997-002-01, :on 970123,failure to Meet TSs 4.5.2d(1)(b) for Testing of Emergency Escape Airlock Occurred.Caused by Missed Surveillance.Emergency Escape Air Lock Testing Was Completed & Declared Operable

:on 970123,failure to Meet TSs 4.5.2d(1)(b) for Testing of Emergency Escape Airlock Occurred.Caused by Missed Surveillance.Emergency Escape Air Lock Testing Was Completed & Declared Operable

ML18066A893
Person / Time
Site:	Palisades
Issue date:	02/21/1997
From:	Kozup C, Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-97-002-01, LER-97-2-1, NUDOCS 9703030529
Download: ML18066A893 (5)

LER-1997-002, on 970123,failure to Meet TSs 4.5.2d(1)(b) for Testing of Emergency Escape Airlock Occurred.Caused by Missed Surveillance.Emergency Escape Air Lock Testing Was Completed & Declared Operable

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ii) 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(iv), System Actuation 10 CFR 50.73(a)(2)(v), Loss of Safety Function
2551997002R01 - NRC Website

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PllWERINli

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Palisades -Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 February 21, 1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk *

. Washington, DC 20~55 r*.

'DOCKET 50-255 - LICENSE PPR PALISADES PLANT Thomas J. Palmlsano Plant_ General Manager LICENSEE EVENT: REPORT 97-002 - FAILURE TO MEET TECHNICAL SPECIFICATIONS"4.5.2d(1 )(b) FOR TESTING OF THE EMERGENCY -

• ESCAPE AIR LOCK*

. Licensee Event.Report 97-002 is attached. This event is reportable in accordance with 1 O CFR Part 50. 73(a)'(2)(i)(B) as a-co.ridition prohibited by Technical Specifications.* -*

SUMMARY OF COMMITMENTS This letter contains n6 new commitments and no revisions to existing commitments.

• -- -*----9703030529 97022l

- --- ' -- **.*:* ---~--, - ----

... PDR ADOCK 05000255 S

PDR

.~r~ ~

Thomas J. Palmisano -

Plant General Manager CC Administrator, Region.Ill, USNRC.

Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment 030100 1muDillIE111rn1nm~11U 11101m 1rn

• • 7

• • • 1.....

A CMS' ENERGY COMPANY

NRC FORM388 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3160-4104 *.

(4195)

EXPIRES 4130/98 ES'IUlf<TED 1U1DEN PER RESPONSE TO COMPLY wmi lHIS MANDATORY INFORMATION COUECTION REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED ARE INCORPORATED LICENSEE EVENT REPORT. (LER)

INTO "!ME LICENSING PROCESS Nill FED BACK TO INDUSTRY. FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT I* * ~. *.:..

BRANCH (T-1 F33);U.S. MJCLEAR REGULATORY COMMISSION, WASHINGTON, DC 2055S-0001, Nill. TO THE PAPERWORK REDUCTION PROJECT (315G-ll11W, OFFICE OF (See reverse for required number of digits/characters for each block)

MANAGEMENT Nill BUDGET, WASHINGTON. DC 20503 FACILITYNAME(1) CONSUMERS POWER COMPANY ER(2)

JR>of4 PALISADES NUCLEAR PLANT 05000255 TITLE (4) LICENSEE EVENT REPORT 97-002-FAILURE TO MEET TECHNICAL SPECIFICATIONS..:i.5.2d(1)(b) FOR TESTING OF THE EMERGENCY ESCAPE AIRLOCK EVENT DATE (5)

LER NUMBER (6)

REPORT DATE m OTHER FACILITIES INVOLVED (8)

MONTH D~Y YEAR YEAR I SEQUENTIAL REVISION MONTH DAY YEAR FACILITY NAME DOCKET NUMBER NUMBER NUMBER 05000 01

• 23 97 97 002 00 02 21

97.

FACILITY NAME DOCKET NUMBER 05000

. OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check one or more) (11)

MODE (9)

N 20.2201(b) 20.2203(a)(2)(v) x 50.73(a)(2)(i) 50.73(a)(2)(iii)

POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50.73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 99.6 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71

- i 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv)

OTHER 20.2203(a)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v)

Specify in Abstract below or 20.2203{a){2){iv) 50.36{c){2) 50.73{a){2){vli) in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAME

)

TELEPHONE NUMBER (Include Area Code)

Charles S. Kozup, Licensing Engineer

. (616) 764-2000 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT {13)

CAUSE**

SYSTEM COMPONENT MANUFACTURER, REPORTABLE

CAUSE

SYSTEM COMPONENT MANUFACTURER REPORTABLE TONPR_DS roNPRDS SUPPLEMENTAL REPORT EXPECTED (14)

MONTH DAY.

YEAR I YES x* I NO EXPECTED If.yes COMPLETE EXPECTED COMPLETION DATE SUBMISSION DATE {15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On.January 23, 1997, the plant was operating at 99.6% power.. During the*preparation of the P.alisades Improved Technical Specifications, it was recognized that Palisades was not in.

compliance with the Technical Specification Surveillance reql,.lir.ement 4.5.2d(1 )(b) for the emergency eseape air lock. At J528 on January 23, 1997, the emergency escape air-lock was ** -

declared inoperable and Technical Specification 4.0.3 was entered due. to the missed surveillance.

At 101 O on January 24, 1997, the emergency escape air lock testing was completed and the emergency escape air lock was d~clared operable.

Technical Specifications.

This testing restored compliance with

i I 4195 U.S. NUCLEAR REGULATORY COMMISSION FACILITY NAME 11 l PALISADES NUCLEAR PLANT LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKETl2\\

LER NUMBER 6l 05000255 YEAR I SEQUENTIAL REVISION NUMBER NUMBER

. 97 -

002 00 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

EVENT PESCRIPTION PAGE 13l 20F4 On January 23, 1997, the plant was operating at 99.6% power. During the preparation of the Palisades Improved Standard Technical Specifications, it was recognized that Palisades was not in compliance with the Technical Specification Surveillance requirement 4.5.2d(1 )(b), for the emergency escape air lock. This paragraph requires "... a reduced pressure test.for the door seals or a full air lock penetration test shall be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after either each air lock door opening.... " At 1528 on January 23, 1997, the emergency escape air lock was declared inoperable and Technical Specification 4.0.3 was entered due to the missed surveillance. Technical Specification 4.0.3 allows for a delay up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the surveillance prior to taking the required t~chnical specification action. The emergency escape air lock was tested to restore compliancewith Technical Specifications and declared operable at 1010 on January 24; 19~7.

This testing restored compliance with Technical Specifications.

• The Palisades emergency* escape air lock does not provide the capability to perform unrestrained between-the-seals tests. In our Licensee Event Report 87-026, dated September 21, 1987, we stated that we would perform a seal contact inspection and adjustment after every strongback removal. The practice at Palisades has been to reopen the outer door to gain access. to the.inner door to remove t~e strongbacks needed to perform the full air lock testing. In addition, the inner door is opened and both the inner and the outer door seals are inspected and adjusted if necessary to ensure seal contact* after the test.

On April 21, 1989, the NRC issued a violation to Palisades for failing to test the emergency escape air lock doors within three (3) days of opening the door. On May 22, 1989, we responded to the Notice of Violation and explained our position. On June 30, 1989, we submitted *our written do~umentation regarding the equivalency of a seal contact check to a between-the-seals test. In this submittal, we explained our plans to continue to use the-present methods for emergency -* *.--*

escape air lock testing.. *

. On June 1, 1989, the NRC approved a Technical Specification.change request, which made the 1 O CFR 50, Appendix J, testing requiremehts a part of Technical Specifications~ At that time, it was not recognized that the failure to pressure test as specified in Appendix J then became a Technical Specification violation in addition to being a violation of Appendix J.

A Technical Specification change request which requested approval of our current practices was submitted on March 25, 1991, but was withdrawn on July 29, 1991. On January 10, 1996, the Technical Specification change request was resubmitted with a Request for Exemption from 1 o CFR 50 Appendix J.

!. 4195 FACILITY NAME 11 l PALISADES NUCLEARPLANT U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION DOCKET I?\\

05000255 LER NUMBER 6l YEAR I SEQUENTIAL ! REVISION NUMBER I NUMBER 97 -

00 2 -

00 PAGE 13l 30F4 TEXT (If more space is required, use additional copies of NRC Form 366A) (17)

CAUSE OF THE EVENT

The cause of this event was that in 1989, the Palisades personnel did not recognize that continuing the testing practices that were in place had become a violation of the Technical.

Specifications when the June 1, 1989, Technical SpecificationAmendment on containment penetration testing was issued by the NRC. This oversight occurred because the issues associated with the emergency escape air lock had been discussed previously with the NRC, and we believed we were technically justified in ou~ approach and our interpretations, and were*

proceeding on a course of action which ~ould resolve the outstanding issues. However, we.

overlooked the* fact that additional actions would be required to place the plant back in.to compliance with the Technical Specifications.

SAFETY SIGNIFICANCE

This 'occurrence has no safety significance. The Palisades technical position *had b~en previously docum~nted to the NRC on May 22 and June 30, 1989. The emergency escape air lock remained eapable of satisfying its design basis to se.al under accident conditions.

CORRECTIVE ACTION

The emergency escape air lock was tested to comply with the surveillance requirement. This..

testing restored compliance with Technical.Specifications on January 24, 1997.

• On January 26, 1997, the E)mergency escape air lock was tested again.. After this test,. the strongbackswere left on the*innerdoor, *eliminating th_e.. need'to open the"outerdoor fo remove the -

strongbacks. A temporary plant n:iodification had been processed to document that continued plant operation was satisfactory with the strongbacks on the inner door until the NRC completes its review of the pending Technical Specification chang~ request and the Request for Exemption to 10 CFR 50, Appendix J. This strongback prevents the opening 9f the emergency escape air lock inner door rendering it non-functional for egress from the containment, until the strongback can be removed by accessing it from outside of containment.

• f

,; 4195 U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

- nnCKETI?\\

PALISADES NUCLEAR 'PLANT

• 05000255

'LER NUMBER jS\\

YEAR I SEQUENTIAL NUMBER REVISION NUMBER 97 -

002 00

• TEXT (If more space Is required, use additional copies of NRC Form 366A) (17)

P4GE l3l 40F4 A majorTechnical*Specification change request is currently being developed to convertPalisades Technical Specifications to emulate the content and format of Improved Standard Technical Specifications. The plant review of this change will involve verification that the plant procedures correctly implement all requirements of the new Technical Specifications. This review will be sufficient to assure that all Technical Specification requirements are implemented.

PREVIOUS EVENTS Other events associated with containment integrity and air locks are License Event Reports 87~

026, dated September 21, 1987, and 83-.066, dated November 5, 1983.