ML18067A719

LER 97-008-00:on 970912,spurious Valve Operation Could Result in Loss of Shutdown Capabilities Per 10CFR50,App R, Section Iii.L,Was Discovered.Caused by Failure to Validate Info from App R.Design Bases for SW Backup Reviewed

ML18067A719
Person / Time
Site:	Palisades
Issue date:	10/10/1997
From:	Kozup C CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18067A718	List: ML18067A717 ML18067A719
References
LER-97-008, LER-97-8, NUDOCS 9710220082
Download: ML18067A719 (5)

Text

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-4104 (4195) EXPIRES 4130/98 ESTlllATED IUUlEN PER RESPONSE TO COMPLY WITH THIS MANDATORY INFORMATION COU£CTION REQUEST: 50.0 HRS. REPORTED LESSONS LEARNED AAE INCORPORATED LICENSEE EVENT REPORT (LER) INTO THE LICENSING PROCESS NID FED BACK TO INDUSTRY. FORWAAD COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION NID RECORDS MANAGEMENT BRANO! (T-e F33), U.S. ~LEAA REGULATORY COMMISSION, WASHINGTON, DC 2055S-0001, Nie TO THE PAPERYIORK REOUC'TION PROJECT (315G-011M, OFFICE OF (See reverse for required number of digits/characters for each block) MANAGEMENT Nie BUDGET, WASHINGTON, DC 20503 FACILITY NAME (1) CONSUMERS ENERGY COMPANY DOCKET NUMBER (2) Page (3)

PALISADES NUCLEAR PLANT 05000255 1of4 TITLE (4) LICENSEE EVENT REPORT 97-008 - SPURIOUS VALVE OPERATION COULD RESULT IN LOSS OF SHUTDOWN CAPABILITIES PER10 CFR 50, APPENDIX R, SECTION 111.L EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

MONTH DAY YEAR YEAR I SEQUENTIAL NUMBER I REVISION NUMBER MONTH DAY YEAR FACIL:ITY NAME DOCKET NUMBER 05000 FACILITY NAME DOCKET NUMBER 09 12 97 97 - 008 - 00 10 10 97 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) 50. 73(a)(2)(i) 50. 73(a)(2)(iii) x I I I POWER 20.2203(a)(1) 20.2203(a)(3)(i) 50. 73(a)(2)(ii) 50.73(a)(2)(x)

LEVEL (10) 100 20.2203(a)(2)(i) 20.2203(a)(3)(ii) 50.73(a)(2)(iii) 73.71 20.2203(a)(2)(ii) 20.2203(a)(4) 50.73(a)(2)(iv) OTHER

• 1 **** ..

>4> I 20.2203(a)(2)(iii) 20.2203(a)(2)(iv) 50.36(c)(1) 50.36(C)(2) 50.73(a)(2)(v) 50.73(a)(2)(vii)

Specify in Abstract below or in NRC Form 366A LICENSEE CONTACT FOR THIS LER (12)

NAME Charles S. Kozup, Licensing Engineer TELEPHONE NUMBER {Include Area Code)

(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 TONPROS TONPROS SUPPLEMENTAL REPORT EXPECTED (14) MONTH DAY YEAR I YES If yes COMPLETE EXPECTED COMPLETION DATE x I NO EXPECTED SUBMISSION DATE (15)

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

On September 12, 1997, at approximately 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, with Palisades operating at approximately 100% power, an Appendix R Program Engineering Analysis was discovered to have failed to properly evaluate the potential for spurious opening of Service Water (SW) cross-tie valves (CV-0879, CV-0880 an.d CV-0951 ). These three valves supply backup SW to cool Engineered Safeguards pump seals and bearings if a loss of Component Cooling Water (CCW) would occur.

Specifically, a fire in one of several areas could result in a single spurious* opening of any of these valves which could potentially result in a loss of CCW inventory to the lower pressure SW System.

This condition was found during a planned review of Appendix R Program engineering analyses.

This review determined the analysis contained errors which could potentially place the plant in a scenario which was not specifically addressed in the Appendix R program analyses. This event is reportable to the NRC in accordance with 10 CFR 50.73(a)(2)(ii)(B) as a condition outside the plant design basis. This Appendix R issue is reportable because the analysis failed to identify a condition which could potentially result in a loss of CCW inventory due to a fire in certain fire areas. This loss of CCW would jeopardize the ability to achieve the 10 CFR 50, Appendix R, Part Ill, L required plant conditions.

9710220082 971010 PDR ADOCK 05000255 S PDR

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME 11\ OOCKET12l LER NUMBER 16\ PAGE CONSUMERS ENERGY COMPANY PALISADES NUCLEAR PLANT 05000255 YEAR I SEQUENTIAL NUMBER REVISION NUMBER 2 OF 4 97 - 008 - 00 TEXT (If more space 1s requi.red, use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On September 12, 1997, with Palisades operating at approximately 100% power, an Appendix R Program Engineering Analysis, EA-APR-95-006, was discovered to not properly evaluate the potential for a fire in one of .several areas resulting in the spurious opening of Service Water (SW) cross-tie valves (CV-0879, CV-0880 and CV-0951; refer to attached sketch). These three valves supply backup SW to cool Engineered Safeguards pump seals and bearings if a loss of Component Cooling Water (CCW) would occur. Specifically, a single spurious opening of any of these valves could, in the worst case scenario, potentially result in a loss of CCW inventory to the lower pressure SW System in as little as 25 seconds.

The engineering analysis stated "During normal operation, the ESS (Engineered Safeguards System) pumps are not running, and the CCW supply and return valves, CV-0913 and CV-0950, respectively are normally closed. Thus, the opening of any one valve (either CV-0879, CV-0880 or CV-0951) could not result in loss of CCW inventory." This statement is incorrect since the CCW supply and return valves (CV-0913 and CV-0950) are normally open. These valves were changed from normally closed to normally open in 1994 due to a single failure concern addressed in Licensee Event Report 94-004-01 dated December 28, 1994. Additionally, CCW supply and return valves (CV-0913 and CV-0950) fail in the open position on loss of power or supply air.

This discovery occurred on September 12, 1997, during a planned review and upgrade of the Appendix R Program engineering analysis, EA-APR-95-006. This review determined the analysis contained errors which could potentially place the plant in a scenario which was not specifically a.ddressed in the Appendix R analyses. This analysis was originally technically reviewed and issued as "Preliminary" on March 26, 1996.

Immediate actions were initiated .

to review the design basis for the SW cross-tie valves (CV-0879, '

CV-0880 and CV-0951) to determine options available. The decision was then made to close the air supplies to the SW cross-tie valves and caution tag the air supply valves until the formal procedural changes could be processed. The isolation of the air supplies removes the possibility of a spurious operation of these valves.

As a result of a miscommunication and a lack of a questioning attitude, the immediate action of closing and caution tagging the air supply valves to the SW cross-tie valves (CV-0879, CV-0880 and CV-0951 ), was not properly implemented. On September 24, 1997, after the permanent procedure changes had been made and while removing the caution tags, the air supply valves were found to be in the open position. Because the air supply valves had been maintained open, the corrective actions we reported to the NRC as completed on September 12, 1997 were not completed until September 24, 1997. The delay in the closure of the air supply valves was communicated to the Resident Inspector and Region Ill management. Corrective actions to resolve the issue are being taken. The Operations Department is reviewing the equipment control

NRC FORM 366a U.S. NUCLEAR REGULATORY COMMISSION 4195 LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION

~

FACILITY NAME (1 I DOCKETC21 LER NUMBER 16)

CONSUMERS ENERGY COMPANY PALISADES NUCLEAR PLANT 05000255 YEAR I SEQUENTIAL NUMBER REVISION NUMBER 4

97 - 008 - 00 TEXT (If more space 1s required, use additional copies of NRC Form 366A) (17) process to determine enhancements to assist in determining when double verification is appropriate.

CAUSE OF THE EVENT The cause of the error in the engineering analysis was determined to be from two sources.

First, the work practices of the preparer of analysis, EA-APR-95-006, were inadequate in that he failed to validate the information from the Appendix R database used in preparing the-analysis.

The version of piping and instrumentation diagram (P&ID), M209 Sheet 2, available at the time the analysis was prepared showed the CCW valves in the open position. However, there is no indication that the P&ID was reviewed by the preparer.

• Second, the reviewer of the analysis failed to catch the error. The reviewer indicated that he understood the Appendix R rules and had worked on Appendix R tasks in the past. Since he had reviewed other analyses from the same preparer and they had been done well, the reviewer felt his review may not have been as rigorous as it should have been.

The failure to catch the error. during the review is attributed to a single occurrence of human error, with a contributing factor of the reviewer's confidence of the preparer based on past positive experience with analyses from this preparer.

Another contributing factor was a design change control process which failed to assure that operational changes to control valve position were addressed and documented in Appendix R Program analyses.

ANALYSIS OF EVENT This issue is reportable because an Appendix R analysis failed to identify a condition which could jeopardize the ability to achieve plant conditions as prescribed in 10 CFR 50, Appendix R, Part Ill, L. This situation is ou.tside the 10CFR50 Appendix R design basis. Had a spurious opening of the SW cross-tie valves (CV-0879, CV-0880 and CV-0951) occurred due to a postulated fire, loss of CCW inventory with subsequent loss of shutdown cooling capability would have occurred without any Appendix R approved coping scenarios in place to mitigate that situation. The current configuration with the SW cross-tie valves (CV-0879, CV-0880 and CV-0951) failed in the closed position precludes the event from occurring.

NRC FORM 366a 4195

• LICENSEE EVENT REPORT (LER)

U.S. NUCLEAR REGULATORY COMMISSION TEXT CONTINUATION FACILITY NAME 11 \ DOCKET12\ LER NUMBER 61 PAGE CONSUMERS ENERGY COMPANY PALISADES NUCLEAR PLANT 05000255 YEAR I SEQUENTIAL NUMBER I REVISION NUMBER 40F4 97 - 008 - 00 TEXT (If more space 1s required, use additional copies of NRC Form 366A) (17)

CORRECTIVE ACTIONS COMPLETED The design bases for SW backup to CCW cooling for ESS pump seals has been reviewed and the procedure changes needed to operate the SW system with air isolated fo the SW cross-tie valves (CV-0880, CV-0879 and CV-0951) have been completed.

CORRECTIVE ACTIONS TO BE COMPLETED A reconciliation will be performed of the Appendix R program mechanical piping and instrumentation diagrams (P&ID) to verify that information entered into the Appendix R safe shutdown equipment list is correct for normal valve positions and failed positions .due to loss of supply air and power. The safe shutdown equipment list and any affected analyses will be updated as required based on reconciliation results.

• The Appendix R engineering analysis (EA-APR-95-006) will be revised to account for current configuration of the CCW supply and return valves (CV-0913 and CV-0950) as normally open and the air supply to SW cross-tie valves (CV-0880, CV-0879 and CV-0951) isolated.

The Component Cooling Water Design Basis Document (DBD 1.01) will be updated to reflect current alignment of CCW supply and return valves (CV-0913 and CV-0950) as normally open and the air supply to SW cross-tie valves (CV-0879, CV-0880 and CV-0951) as isolated.

A method will be developed or enhanced to screen Palisades changes, both physical and procedural, whereby areas potentially affected by the change can be identified so that appropriate Appendix R reviews are performed. Change types to be screened include the following:

modifications, Operating Procedure changes, Surveillance Procedure changes, Engineering Analyses which change design basis inputs, and FSAR changes.

Engineering Support personnel will be notified of this occurrence and instructed on the lessons learned from it.

• PALISADES ENGINEERED SAFEGUARDS SYSTEM

. PUMP COOLING CCW SURGE TANK EL. 653'-0*

EL. 5'10'-0*

ccw HX lS) ("')

LD ........

(J' (J' lS) lS)

> OTHER >

u u ccw LOADS AIR TO AIR TO CLOSE CLOSE 4 ESS IS OPENS SIS OPENS PUMP (J' COOLERS v (J'

EL. 571'-0* CV0947 lS) u 3 ESS PUMP COOLERS AIR TO CLOSE CV0948 lS) ro ro lS) u CV0951 CV0879 AIR TO OPEN SWS RETURN SWS SUPPLY