ML20215F727
| ML20215F727 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/20/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8612240044 | |
| Download: ML20215F727 (6) | |
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GLEN ELLYN, ILUNOt5 60137 30V 2 0 26 Docket No. 50-255 Consumers Power Company ATTN: Dr. Fredrick Buckman Vice President Nuclear 1945 West Parnell Road Jackson, Mi. 49201
Dear Dr. Buckman:
On May 19, 1986, the Palisades Nuclear Plant tripped from 97 percent power.
The trip resulted from a loss of the main turbine electrohydraulic control (EHC) system. This plant trip had been preceded by a series of equipment failures which occurred periodically since late 1984. During the May 19, 1986 trip, numerous pieces of plant equipment failed to operate as expected, which resulted in an increased demand on the operators in placing the plant in a safe shutdown condition. Because of NRC concerns regarding the multiple equipment failures, an Augmented Investigation Team was dispatched to the site and a Confirmatory Action Letter (CAL) was issued on May 21, 1986. The CAL confirmed your company's commitments to review each equipment failure for root cause and to obtain NRC approval prior to startup of the plant beyond the hot standby condition.
In implementing the commitments made following the May 19, 1986, trip, your company initiated a Material Condition Task Force to indepandently review event related equipment failures and other equipment deficiencies, and to assure that problems were resolved promptly and thoroughly. By letter dated July 3,1986, you replied to the CAL and submitted a report on the Task Force activities. The items identified were divided into those requiring attention prior to startup, those that would be addressed in a future outage and those to be completed as scheduled in the existing five year plan. Subsequently, you submitted letters dated August 15, 1986, and September 19, 1986, which reported progress on your activities and identified emergent items requiring additional corrective actions.
During the performance of the corrective maintenance activities a1d the augmented testing that was instituted as part of the Task Force recommendations, you found and reported to tne NRC, certain deficiencies in safety system design capabilities. These deficiencies involved insufficient servic.. water flow through containment air coolers, component cooling water flow less than specified in the FSAR, service water capability less than j
specified in the FSAR, and low pressure safety injection pump flow less than specified in the FSAR. The failure to recognize that certain pump impellers i
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e Consumers Power Co..NOV201966 had been modified in their original installation and that throttling of heat exchanger valves without determining system flow changes demonstrate a lack of knowledge of system design and of control over system modifications.
In addition, the NRC conducted a Safety System Functional Inspection (SSFI) of the high pressure safety injection system during September and October of 1986.
Certain of the findings of that inspection also raise questions about compliance with design bases. A summary of these findings is set forth in Enclosure 1.
We have been informed by representatives of your staff in various telephone conversations and meetings about your staff's evaluations including reanalyses and test results. Since these issues involve compliance with the licensing basis for Palisades, we require that information supporting the operation of Palisades in the manner proposed be submitted for review and approval.
Accordingly, to enable us to determine whether or not the Palisades license should be modified, suspended or revoked, you are requested, pursuant to the provisions of 10 CFR 50.54(f), to evaluate and address the following:
1.
Results of inspections, investigations, maintenance, and testing during the current outage (Maintenance Task Force and any safety issues that became known as a result of these activities, Safety System Functional Inspection findings, Augmented Investigation Team findings,etc.).
2.
Lessons learned from these activities.
3.
Management system, programmatic and hardware changes made or planned as a result of the above findings and actions you will take to improve regulatory and operational performance during and after facility startup.
Specific information requests on these broad areas of concern are identified in Enclosure 2 to this letter.
Pursuant to 10 CFR 50.54(f), you are requested to furnish, under oath or affirmation, no later than 30 days from the date of this letter, your plans and programs to resolve the concerns identified above and as elaborated upon in the enclosures. The plans and programs should specify those actions to be completed prior to restart of Palisades and include a schedule for any longer term actions. Where you have made prior submittals to the NRC on these
NOV 2 01986 Consumers Power Co. issues, the response directed by this letter may reference those submittals and contain a brief summary of the information provided therein. We are
. prepared to meet with you to discuss your plans and programs subsequent to the submittal of your written response.
Sincerely, s.%f James G. Kepp er Regional Administrator Region III
Enclosure:
1.
Findings of SSFI Inspection 2.
Areas of Regulatory Concern Relating to Palisades cc w/ enclosures:
V. Stello, Jr., ED0 H. Denton, NRR J. Taylor, IE F. Maraglia, NRR A. Thadani, NRR J. Partlow, IE Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager fDCS/RSB:(RIDS).
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Nuclear Facilities and Environmental Monitoring Section
w ENCLOSURE 1 Safety System Functional Inspection Issues 1.
Lack of seal-in feature for the safety injection system recirculation actuation signal.
2.
Adequacy of HPSI pump recirculation flow.
3.
Air-operated valve design deficiencies including:
(a) Single air source for CV-3027 and CV-3056.
(b) Non-safety-related air supply for CV-3070, CV-3071, CV-3001, CV-3002, CV-0347A, and CV-0347B.
4.
Instructions to operators which, if followed, could result in recirculating highly contaminated liquid to the SIRWT.
5.
Deficiencies with battery surveillance testing including:
(a) Performing an equalizing charge prior to conducting the service test.
(b) Failure to correct discharge currents to minimum design temperature.
(c) Failure to correct specific gravity readings for electrolyte levels.
6.
Lack of testing isolation check valves in air systems.
7.
Lack of preventive maintenance, especially lubrication, for motor-operated valves.
8.
The non-safety-related classification of several electrical breakers required to open for load shedding.
9.
Lack of training provided to electrical and mechanical maintenance technicians.
s ENCLOSURE 2 SPECIFIC INFORMATION REQUESTS I.
Results of Inspections, Investigations, Maintenance, and Testing:
A.
Methodology employed to identify and disposition deficiencies recognized as a result of the May 19, 1986, outage, in summary form.
Extent of employee involvement in the identification /
disposition process.
B.
Status of disposition of all issues identified from item A above.
C.
Issues identified during the outage, whether they were identified as a direct result of the methodology described in response to item A above or other activities including NRC inspections (e.g.'SSFI issues identified in Enclosure 1), and status of resolution of these issues.
D.
Listing of those deficiencies reflective of a failure to maintain a design basis configuration (e.g. ettributable to post-licensing modifications and maintenance).
E.
Listing of those deficiencies which were not identifiable through existing testing programs (Technical Specification,Section XI, etc.) and why.
F.
Listing of those deficiencies to be carried over beyond the current outage and justification for continued operation.
G.
Provide the following:
1.
Your evaluation that justifies operation with less than the Component Cooling Water flow rate described in the FSAR including the results of the analysis for the worst-case, post DBA centainment environment.
2.
Other evaluations for systems identified in Item I.D. as not conforming to FSAR design bases and accident analyses assumptions.
(Those associated with License Amendments /
Technical Specifications should be submitted separately with the Amendment request).
3.
Identify all Technical Specification changes required as a result of deficiencies found (e.g., Service Water Temperature, Containment Air Coolant Fan Motor V4A, and Fire Water System).
Indicate the filing date for each Amendment request.
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H.
Extent of reviews done with respect to balance of plant systems (B0P) to ensure reliability such that unnecessary challenges to safety systems and to operators will be minimized during the period of plant startup and subsequent power operation.
l II. Lessons Learned from Outage Activities A.
Extent to which programatic weaknesses contributed to conditions in which the design bases were not satisfied. Your response should include consideration of the following areas: post-licensing modification process, testing programs, deficiency reporting system, corrective action system (including significance evaluation), work prioritization system and training.
III. Management System, Programmatic and Hardware Changes Made or Planned A.
Describe any changes made or planned in the following areas of work process control:
1.
Deficiency identification 2.
Deficiency evaluation 3.
Root cause determination 4.
Prioritization 5.
Post work testing B.
Describe any changes made or planned in routine testing programs.
C.
Describe any changes made or planned to training programs as a result of deficiencies (equipment or programatic) identified during the outage.
D.
Describe any changes made or planned to the plant modification control program.
E.
Describe those management systems which will be employed as a primary mechanism to assess plant performance.
F.
Describe short term and long term plant modifications intended to ameliorate the design deficiencies discovered during this outage.