ML20206F200
| ML20206F200 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/19/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8606240313 | |
| Download: ML20206F200 (4) | |
Text
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'JUN 191996 Docket No. 50-255
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Consumers Power Company ATTN: Dr. F. W. Buckman Vice President Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
On May 21, 1986, Region-III directed the Palisades facility to shut down pending completion of an investigation into the cause of the May 19 reactor trip and subsequent equipment failure. Subsequently, we issued a Confirmatory Action Letter describing actions that you would take prior to restart of the facility.
Pursuant to NRC Manual Chapter 0514 "NRC Program for Management of Plant Specific Backfitting of Nuclear Power Plants," we have prepared an evaluation setting forth the justification for our actions. A copy of this evaluation is enclosed for your information.
Please let us know if you have questions regarding this evaluation.
Sincerely, Cr10 m 1 s) nnd ?ri i
M..m O. ra n k r James G. Keppler Regional Administrator
Enclosure:
Palisades Evaluation Report cc w/ enclosure:
Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB(RIDS)
Q Licensing Fee Management Branch (U
Resident Inspector, RIII 1
Ronald Callen, Michigan 8606240313 860619
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' EVALUATION:0F NRC' STAFF IMPOSED BACKFIT NECESSARY TO ENSURE THAT THE PALISADES NUCLEAR POWER FACILITY POSES NO UNDUE RISK TO PUBLIC HEALTH AND SAFETY 8ACKGROUND On May 19, 1986, the Palisades nuclear reactor tripped from high pressure after a loss of turbine control power resulted in closure of the turbine governor valves. Although the plant responded nonnally, several components did not operate as expected. The turbine bypass valve did not automatically open; one atmospheric dump valve did not open; a letdown intermediate pressure control valve failed (causing the CVCS relief valve to lift); a rod bottom light did not light; a charging pump designated for emergency use only could not be started despite numerous attempts; and, a pressurizer spray valve failed to reseat.
As a result of the May 19 event, on May 21, 1986, Region III directed the Palisades facility to shut down pending completion of an investigation into the cause of the May-19 reactor trip and subsequent equipment failure and permission of the Regional Administrator to restart following a briefing on corrective actions taken or planned by the licensee.
Further details are provided in the attached confirmatory action letter dated May 21, 1986.
(Attachment 1)
Accordingly, pursuant to NRC Manual Chapter 0514, paragraph 042, this evaluation is necessary.
OBJECTIVES AND REASONS FOR THE BACKFIT The objective of the backfit was to ensure that the causes and implications of the May 19 reactor trip, and the multiple equipment failures, including the burden these failures placed on the operators, were fully understood and corrected prior to the facility resuming' power operation.
Prior events at the facility, beginning in late 1984, due in part to inadequate maintenance, involved other problems with safety related equipment. This included five i
events related to leaking Safety Injection Tank (SIT) check valves, valve leakage problems on the HPCI injection line, SIT pressure control valves, a L
manual isolation valve and the three-way divert valve in the chemical and volume control system. On March 9, 1986 the licensee elected to shut down and repair the problems but had to shut down again 16 days after returning to power operation after exceeding the Technical Specification limit for unidentified l
primary coolant system leakage.
Following the return to power operation on April 11, 1986, the licensee identified a packing failure on Condensate Pump "A."
The pump was' repacked twice prior to replacing it with an onsite spare. These events demonstrate a history of multiple equipment failures at the facility that are of concern to the NRC due to the potential for serious challenges to safety systems that they pose and due to the heavy reliance they place on
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continued above average operator response to maintain the plant in a safe operating condition. These concerns are supported by the final report of the i
NRC Region III Task Force Review of the Operational History (1983-1985) for i
Palisades, dated May 1,1986, and the licensees SALP Category 3 ratings in the areas of maintenance, surveillance and quality program and administrative l
controls during the most recent SALP period ending October 31, 1985.
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-SAFETY SIGNIFICANCE AND APPROPRIATENESS OF ACTION TAKEN Appendix A to 10 CFR 50 sets forth principal design criteria for nuclear power plants which establish the necessary design, construction, testing, and performance requirements for structures, systems, and components important to safety that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.
Included in these criteria are requirements to design systems which are capable of protecting the plant during anticipated operational occurrences with a single failure of an active system component. This single failure criterion is predicated on the assumption that the systems themselves are maintained in such a fashion so as to ensure a high degree of reliability. Shortcomings in maintenance of.such systems compromise their reliability, thereby increasing the probability of multiple failures, a condition contrary to plant design bases.
As noted above, the Palisades facility has had a history of poor maintenance and numerous component failures. While it is recognized that not all of the recorded failures were with equipment important to safety, enough were to call into question the relisbility of such equipment.
The question of reliability of equipment important to safety is by itself safety significant; however, in the case of the Palisades facility, this significance is elevated by virtue of the numerous failures of equipment not explicitly important to safety. There are two reasons for this.
- First, failures of such equipment can and have caused unwarranted safety system challenges, increasing the frequency and complexity of anticipated operational occurrences. The net effect of this is that the probability of ar accident is increased. This represents a direct adverse impact to safety.
The second reason is that increasing the complexity of an event places an unwarranted burden on the plant operator by requiring that operator to respond to multiple equipment failures with the attendant distraction that represents.
The net effect is to potentially compromise the ability of the operator to respond in a fully appropriate and timely fashion to an event.
This also j
represents a direct adverse impact on safety.
Because of the uncertain status of equipment at the Palisades facility and the number of unwarranted recent safety system challenges, the only viable option to ensure that no undue risk to public health and safety existed was to require
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the licensee to shut down the plant and evaluate its equipment status.
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BASIS FOR INVOKING THE EXCEPTION In light of the multiple equipment failures that occurred on May 19, the licensee's demonstrated lack of conservatism regarding plant operations with deficient equipment and the licensee's SALP Category 3 ratings described above, the Region III staff determined that no alternative short of shutdown was
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feasible at the time because of the imediate need to ensure that this event and its implications were adequately understood and that adequate corrective action taken or planned.'
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Accordingly, I concluded that imposition of this backfit was necessary to ensure that the Palisades' facility poses no undue risk to public health and safety.
Date James G. Keppler Regional Administrator
Attachment:
As stated 3
t0hFllMATORY AC110N LETTER CAL Rill-86-002 W t 11986 Docket No. 50-255 Cor.sumers Power Company ATTN: Dr. F. W. Buckman Vice President huclear Operations 212 West Michigan Avenut Jackson, MI 49201 Gentlemen:
This letter confims the conversation or. May 21, 1986 between you and E. G. Grecis.ar.
of this cifice. The conversation related to our concerns over multiple equipment failures at the Palisades facility..as demonstrated by the May 19 reactor trip event and associated equipment failures, the potential for serious challenges to safety systems that they pose, and the burden failures of this type place cr.
your operator steff in order to maintain the plant in a safe operating conditier..
With regard to the matters discussed, we understand that you will complete the following actions:
1.
You will issnediately take the facility to the cold shutdown condition; 2.
You will not restart the facility (i.e. place the facility in a condition higher than hot standby) until:
(a) a thorough investigation into the causes and implications cf the May IS,1986 reactor trip is completed; f
(b) a thorough investigation of plant safety systems and balance of plant syster.s important to safety, with reoard to operability and required riaintenance, is corapleted; l
(c) The Regional Administrator, or his designee, is briefed on the i
results of the investigations and the corrective actions taken or planned; and (d) you obtain the approval of the Regional Administrator, or his designee.
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CONTIMACY ACTI~1 LtTTER CAL-Rill-86 002 MAYA 1 m
- f. W. Beckman
-t-Should your understanding differ from that stated above, please inform this office 1spediately.
Sincerely, Janes G. Keppler kegional Administrator cc w/ enclosure:
Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, R111 Ronald Callen, Michigan Public Service Comission Nuclear Facilities and Environmental Monitoring Section F
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