ML20203K943

Forwards Prestartup Commitment Status Rept of Delayed Action Items in Response to 860521 Confirmatory Action Ltr Re 860519 Trip Following Failure of Redundant Electro Hydraulic Control Sys.Approval to Restart Plant Requested

ML20203K943
Person / Time
Site:	Palisades
Issue date:	08/15/1986
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CAL, NUDOCS 8608220272
Download: ML20203K943 (6)

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COI1 Sum 8IS POW 8f x.aa.th w serry Director Nuclear Licensing General offmes: 1945 West Parnall Road. Jacksor., MI 49201 . (517) 788 1636 August 15, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

CONFIRMATORY ACTION LETTER PRE-STARTUP COMMITMENT STATUS REPORT May 19, 1986, the Palisades Plant tripped on high pressurizer pressure follow- p ing a failure of the redundant Electro Hydt a lic Control (EHC) system power supplies which resulted in closure of :he turbine control valves. A number of equipment problems, some of which were known prior to the event, hampered the operator's response to the subsequent plant transient.

May 21, 1986, a Confirmatory Action Letter was issued which required Consumers Power Company to proceed immediately to cold shutdown and to remain shutdown until investigations were conducted of the May 19, 1986 reactor trip, and of the general status of plant safety-related and non-safety-related equipment.

May 22 through 25, 1986, an NRC Augmented Investigation Team performed a special onsite review relating to the concerns over the multiple equipment failures at the Palisades facility, as demonstrated by the May 19 reactor trip and associated equipment failures, the potential for serious challenges to safety systems such failures pose, and the burden these failures place on the operating staff in order to maintain the plant in a safe operating condition.

This action resulted in an Inspection Report dated June 30, 1986 that de-scribed the findings in the areas examined during the review.

Concurrent with the NRC action, Consumers Power Company initiated a Material Condition Review Task Force to address the actions required by the Confirma-tory Action Letter. ,

Consumers Power Company's initial results and response to the Confirmatory ,

Action Letter was submitted July 3, 1986. In this letter, we identified /

222 items that could be considered problems or potential problems. This /

identification resulted in 544 recommended actions of which 316 were to be 1 completed prior to plant startup or a Justification for Continued Operatioy d 71 i

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1 Administrator, Region III 2 Palisades Plant Confirmatory Action Letter Pre-Startup Commitment Status Report August 15, 1986 (JCO) would be submitted. All but 10 of the identified 316 action items will be completed prior to startup. In addition to the Plant Equipment Status investigation, we committed to develop an Augmented Test Program. In accor-

. dance with our commitment made in the July 3, 1986 letter, the majority (approximately 75 percent) of the specified items in the Augmented Test Program will have been performed prior to startup with the remainder being acheduled for completion no later than the end of the next refueling outage.

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i The attachment to this letter describes the delayed action items by component I and the corrective action planned for their completion. Also included in the attachment is any exception to the corrective action plus the resulting Justification for Continued Operation.

Discussions with NRC staff have indicated that a meeting between the NRC and j Consumers Power Company, regarding our corrective action measures prior to startup, is not necessary. Consumers Power Company therefore requests approv-al, as specified in the May 21, 1986 Confirmatory Action Letter, to restart the Palisades Plant mid September 1986.

If there are any changes in the status of pre-startup action items, that would mean an additional item not being completed prior to startup, the required i information will be transmitted as soon as it is available.

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E 34'vAf Kenneth W Berry I Director, Nuclear Licensing a

j CC Director, Office of Nuclear Reactor kegulation Director, Office of Inspection and Enforcement 1

NRC Resident Inspector - Palisades Attachment l

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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 EXCEPTIONS TO PRE-STARTUP ACTION ITEMS FROM JULY 3, 1986 PLANT MATERIAL CONDITION TASK FORCE FINAL REPORT August 15, 1986 3 Pages AT0886-0127-NLO2

- k EXCEPTIONS TO PRE-STARTUP ACTION ITEMS 1 .

FROM 7/3/86 PLANT MATERIAL CONDITION TASK FORCE FINAL REPORT OBSERVATION NO. COMPONENTS ACTION EXCEPTION CDS-07 Moisture Separator Put the valves on a Stroking the valves at power would create l

Drain Tank Drain quarterly PM to verify a transient which could result in a plant CV-0608 and CV-0609 proper valve operation. trip, and therefore, they will be tested during shutdowns only. The majority of past problems with these valves are attributable to instrument air moisture, which has been resolved with installation of the new instrument air dryer.

CLP-01 Containment Sump Perform leak tests prior to The bypass valve handle interference Level Transmitters and following modifications problem was resolved by using a handle LT-0382 and LT-0383 to the transmitter bypass of different design. Although e leak valve handles (required to test was not. required for this modifica-eliminate an interference tion, the sensing lines have been shown problem with piping). to be leak tight.

CVC-07 Letdown Diversion Stage and test a replace- Parts are available for a complete valve Valve CV-2056 ment valve as a contingency rebuild with the exception of a lower for leakage problems which seat (expected to be shipped 8/8/86). A may occur during startup. new body is not available, so a spare valve cannot be staged and tested. Will monitor leakage during start-up and if necessary repair.

CWS-02 Cooling Tower Basin Delete the pump trip func- The pump trip function will be retained.

Level Switches tions from these switches; Action was proposed to prevent trip due LS-5307 and LS-5308 leave the alarm intact. to spurious level indication. Past problems have been due to wet instrument air, which has been resolved by install-ing instrument air dryer. A follow-up evaluation will continue to determine if redundant level instrumentation should be installed to minimize the potential for a spurious trip.

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I EXCEPTIONS TO PRE-STARTUP ACTION ITEMS 2 -

FROM 7/3/86 PLANT '

MATERIAL CONDITION TASK FORCE FINAL REPORT OBSERVATION ~

NO. COMPONENTS ACTION EXCEPTION

EPS-01 Emergency Diesel If feasible, replace fre- Parts lead time is such that this is not Generator Instru- quency and load indication feasible (36 weeks delivery). Installa-

! mentation prior to startup. tion will be performed during the 1987 i

maintenance outage. During the interim, portable instrumentation will be utilized to supplement installed instrumentation j during testing to assure proper diesel  ;

generator operation.

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ESS-05 Shutdown Cooling 900R/hr hot spot should be The hot spot intensity and location has Heat Exchangers removed. changed (now 500 R/hr). A hydro and/or J chemical flush will be necessary to j eliminate the hot spot, requiring isola-l tion of the shutdown cooling heat

exchangers. This, in turn, will require an alternate shutdown cooling path which

{ will be completed during the next refuel-

} ing outage. Meanwhile, a physical j barrier will be placed around the hot j spot for personnel protection. The hot 4

spot is not a significant contributor to general area dose rate in the West Safe-4 guards Room.

j ESS-06 Safety Injection / Perform preventive mainte- Repacking and testing of CV-3031 was

} Refueling Water Tank nance (repacking) on the performed in January, 1986 and will not

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Discharge Isolation valves and check stroke be repeated prior to startup. CV-3057 r

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Valves CV-3031 and times. Adjust PM frequency will be repacked prior to start-up.

CV-3057 as deemed apprcpriate. Both valves will be stroke tested via Tech Spec Surveillance testing.

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s-EXCEPTIONS TO PRE-STARTUP ACTION ITEMS 3 -

FRCM 7/3/86 PLANT MATERIAL CONDITION TASK FORCE FINAL REPORT OBSERVATION NO. COMPONENTS ACTION EXCEPTION ESS-07 SIRW Tank Recircula- Relocate FT-0404 upstream The Facility Change package has been tion Flow Indication of the SIRW Tank fast re- prepared and materials procured. PRC FI-0404, FT-0404 circulation line to prevent recommended not implementing with the over-ranging. SIRW Tank filled since a freeze seal would be required to prevent the tank from draining. Implementation will be postponed until the next refout when the tank has been emptied to the refueling canal. Calibration will be performed prior to startup, and Operations will insure that the instrument is valved out whenever the SIRW tank is on fast-recirculation to assure that the instrument is not over-ranged.

RIA-23 RIA-2316, Fuel Hand- Insure operability. This monitor is required for fuel move-ling Area Monitor #1 ment only and is normally disabled during plant operation. Operability will be insured prior to moving fuel in the next refueling outage.

SPS-03 DC Bus Ground Alarm Obtain the services of an Inquiries at other utilities and vendors independent authority to indicate an independent authority is not assist with the grounding available. Plant Operations and Elec-problem assessment and trical Maintenance Departments have resolutions, agreed on lines of responsibility and actions to be taken when a DC alarm is received. The plant goal is to have no DC alarms upon restart from an outage.

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