IR 05000255/1986032: Difference between revisions

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{{Adams
{{Adams
| number = ML18052A941
| number = ML20211L581
| issue date = 04/20/1987
| issue date = 02/17/1987
| title = Forwards Addl Info Re Insp Rept 50-255/86-32 on 870217. Issues Re Equipment Operability & Reliability Addressed. Remaining Actions Considered Enhancements to Eeq File Auditability
| title = Forwards Safety Insp Rept 50-255/86-32 on 861208-870113. Eight Significant Deficiencies Noted in Program Implementation.Findings Classified as Potential Enforcement/ Unresolved Items & Ongoing NRC Review Being Performed
| author name = Johnson B
| author name = Harrison J
| author affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.),
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Buckman F
| addressee affiliation = NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
| addressee affiliation = CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.),
| docket = 05000255
| docket = 05000255
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8704270005
| document report number = NUDOCS 8702270158
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| package number = ML18052A873
| page count = 8
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 2
}}
}}


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=Text=
=Text=
{{#Wiki_filter:* General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 April 20,-1987 * Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -IE INSPECTION REPORT 86032, ADDITIONAL INFORMATION IE Inspection Report 86-032 dated February 17, 1987 transmitted several unresolved and open items to which a written response was not required * Subsequent to receiving the inspection report on February 20, 1987, several conversations have taken place between Consumers Power Company and the NRC regarding the status of these items. It should be noted that all issues regarding equipment-ope.rability and reliability have been addressed and that all remaining actions are considered enhancements to EEQ file auditabilit Attached are the statuses of the items identified in the inspection report and subsequently discussed with Mr ASGautam of the Region III staff, Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, NRG NRG Resident Inspector-Palisades OC0487-0039-NL02 POTENTIALLY ENFORECABLE/UNRESOLVED ITEMS Item No 86032-01 86032"'."05 Description Unqualified grease found in Limitorque actuator ASCO solenoid valves found installed without seals to prevent moisture intusio Certain_ EEQ ._files found not auditable due to incorrect acceptance criteria and and missing informatio Rockbestos Firewall III EEQ files did not establish qualification of appropriate cables. 86032-09 Effects on low IR's during LOCA testing not addressed in General Electric Cable EEQ files. 86032-10 Plant installed Viking potted connectors found unqualified for instrumen-.
{{#Wiki_filter:m
tation circuit IC0487-0059B-NL02 Status . The _SUN 50 EP grease has been removed, actuators cleaned and * qualified Exxon NEBULA EP-0 grease installed in EEQ listed Limitorque Valve Actuator Conduit seals have been installed for: 1) all EEQ listed ASCO solenoid valves in containment which . need to energize after initiation of a design basis *accident (DBA), and 2) all EEQ listed ASCO solenoid valves outside of containment which were in a 100% humidity accident environment and which need to energize after initiation of a DBA. The above actions were taken as a result of a conference cail between CPCo and ASGautam on. January 12, 1987. -The new accident profiles will be completed and incorporated by July 1, 1987, per conversation between KAToner, CPCo, and ASGautam on April 3, 1987. Analyses necessary to close this item were completed April 6, 1987. Analyses necessary to close* this . item have been complete Per conversa_tion between KAToner, CPCo, and ASGautam on April 3, 1987, the analyses will be incorporated into EEQ files by July 1, 1987. Analyses necessary to close this item have been completed. conversation between KAToner, CPCo, and ASGautam on April 3, 1987, the analyses wili be incorporated into EEQ files by July 1, 198 ** * 86032-11 Rosemount transmitter EEQ files did not justify demonstrated accuracy of these instruments for plant accident condition Limitorque actuators determined to be unqualified due to blocked T-drains * IC0487-0059B-NL02 2 As presented to the NRC at Region III headquarters on March 16, 1987, analyses are complet Also completed are administrative controls necessary to assure required safety functions are achieved from equipment associated with Rosemount transmitter Actions taken are described in CPCo internal correspondence; KAT87*008 and RJF87*011, which are attache Primary coolant system pressure transmitters PT-0104A and B and and B are being evaluated for replacement.with new transmitters to significantly eliminate instrument inaccurac Motor T-drains have been installe Reference LER 87-003 for actions take OPEN ITEMS 86032-08 General Electric Cable 1 and 2 EEQ files had discrepancies in the qualification requirements for radiatio Lack of controlled procedure for replacement of "O" rings and torquing of transmitter Deficiencies in the PPACS listing of maintenance activities for containment air coolers, position limit switches and motor oil in EEQ pumps. 86032-03 Lack of instructions for replacement of CELMARK connector "O_" -rings. IC0487-0059B-NL02 3 Per conversation with KAToner, CPCo, and ASGautam on April 3, 1987, necessary actions to close this item will be complete by July 1, 1987. This item has been completed by adding necessary administrative controls to instrument calibration sheets associated with Technical Specifications Surveillance Procedure Actions necessary to complete these items are underway and expected to be completed by May 15, 1987. Actions considered necessary to resolve this concern are under evaluatio Details of these specific actions will be provided to the NRC by May 15, 198 * To RJFrigo, Palisades From KAToner, Palisades CONSUMERS POWER Date March 19, 1987 COMPANY Subject PALISADES PLANT -EEQ TRANSMITTER ERROR Internal ANALYSIS -IMPACT ON OPERATING Correspondence cc RAFenech, Palisades KAT87*008 .KEOsborne, Palisades Engineering Analysis EA-KAT-87-01 was performed to assess the impact on the ability to achieve safety functions during LOCA and MSLB conditions in light of transmitter errors resulting from harsh environmental condition As concluded in the analysis, required safety functions can be achieved even in the presence of such errors if the following recommended procedural revisions are incorporated:
.
REGARDING ENTRY INTO SHUTDOWN COOLING Recommendations:
.
1. Either the strict use of PI-0104 (preferably narrow range, however either narrow or wide range is acceptable)
FEB 17190 Docket No. 50-255 Consumers Power Company ATTN: Dr. F. W. Buckman Vice President Nuclear Operations-212 West Michigan Avenue Jackson, MI 49201 Gentlemen:
and PTR-0125, or the average of all qualified PCS pressure indications (the aforementioned indicators as indicators PI-0105A through D) are to be used .to determine when the Shutdown Cooling System (SDCS) isolation valves M0-3015 and M0-3016 are to be manually opened to commence SDC. --2. The indica.tion-_at-which the shes-i-solation valves are to be openea should be revisedfrom 270 psia to 180 psia to ensure that the upper and lower pressure limits as described in Item 1 above are not exceede Note: The strict use of PI-0104 and PTR-0125 is preferred over averaging all tions in this case, since the shifts in output owing to transmitter error are less for these instruments than that expected for the 0105 loops previously identifie Incorporating Recommendation 2 will ensure that neither the maximum SDCS design pressure or the minimum PCS pressure to ensure subcooling will be exceeded if PI-0104 and PTR-0125 are used (see attached sketch). The 0105 loop errors result in peak-to-peak output shift variations a magnitude which exceeds the pressure band between the overpressurization and subcooling limits regardless of what pressure within the band would be fied as signifying when the operator should open the valves. As a result, using the 0105 loops for this function would require averaging all readings; a practice which would likely reduce the overall inaccuracy of the reading but would not necessarily ensure that the actual PCS pre$sure would be within the acceptable bounds (see attached sketch) . IC0387-1473A-TC01 REGARDING ENTRY INTO "ONCE-THROUGH" COOLING Recommendations:
This refers to the special safety inspection conducted by Mr. A. S. Gautam and other NRC representatives of this office on December 8, 1986 through January 13, 1987, of activities at the Palisades Nuclear Plant authorized by NRC License No. DPR-20 and to the discussion of our findings with Mr. K. E. Osborne at the conclusion of the inspectio The enclosed copy of our inspection re) ort identifies areas examined during the inspection. Within these areas, t1e inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne Although the inspection determined that you have implemented a program to meet the requirements of 10 CFR 50.49, eight significant deficiencies in the program implementation were observed. These findings are classified as Potential Enforcement / Unresolved Items and an ongoing NRC review is being performed to evaluate the findings in regard to possible future enforcement action In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC-Public Document Roo We will gladly discuss any questions you have concerning this inspection.
1. A specific caution should be added to procedures to . indicate that all four wide range steam generator loop indications (LI-0757A and B for Steam Generator A and.LI-0758A and B for Steam erator B) should be scanned with an average value obtained to ascertain when to enter PCS "once-through" cooling. * 2. Core exit thermocouples should also be monitored as a backup check to the wide range level indicatio Proceeding to "once-through" cooling should be based on both: * Steam* generator low level which indicates that the generator may not be capable of serving as an effective heat sink, and 2 * Core exit thermocouples which confirm steam generator ineffectiveness by showing inadequate PCS cooldow Notes: A. In this case, the -84% indication signifying when "once-through" cooling is to be initiated is considered acceptable. (At this level, 36% of the tubes are submerged; a level at which effective heat transfer can still be achieved.)


Although maximum potential transmitter error could result in an actual level of -120% when -84% is indi:Cated, appreciable invent_ory-(-23%) will -st-ill exist in the steam generator, -a_nd tfie-likelihood of steaming the steam generator shell dry before corrective actions are taken is almost non-existen S.ince safety function status checks are performed periodically, it is expected that the operator will be aware of either low or descending steam generator level in a timely manner. B. Based on discussions conducted subsequent to completion of the analysis, it is requested that the Operations Department review emergency procedures to determine if existing guidance related to the assessment of "once-t;hrough" cooling entry conditions fulfills the intent of the above recouunendation If the existing guidance is considered effective, no procedural revision should be undertaken since unnecessary revision may render the procedures confusin IC0387-1473A-TC01 q-_s.c:>tO-zc/
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B702270158 870217    ,
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J. J. Harrison, Chief 4    Engineering Branch Enclosure: Inspection Report  --
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No. 50-255/86032(DRS)  ,
2 1 \ .=foc;ioE
See Attached Distribution 1CS
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}EIIISlf RI ' RIII    &
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  ;r so3    T ur ess  H rison Gautam/nma 2/i.js7 *So Westberg An\e An  f,go/
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Consumers Power Company  2  FEB 171987
*1 To KAToner From RJFrigo CONSUMERS POWER Date March 26, 1987 COMPANY Subject PALISADES PLANT-Internal EEQ TRANSMITTER ERRORS Correspondence cc RAFenech RJF87*0ll KEOsborne Per memo KAT87*008 the following change has been made to the EOPs in response to transmitter errors resulting from degraded containment conditions:
-
a) EOPs 4.0 (LOCA), 6.0 (ESDE), & 9.0 (Functional Recovery)
Distribution cc w/ enclosure:
have been modified to state "PCS pressure 270 psia (180 psia for degraded containment)
Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB (RIDS)
OR less as indicated on PI-0104 OR PTR-0125" as a condition to go on shutdown cooling. b) No changes are warranted for the four S/G wide range instrument The use of these instruments is in conjunction with other indications (Qualified CETs & PCS pressure trends) to determine if S/G heat removal capability is lost. IC0387-0003A-OP01
Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission      n Nuclear Facilities and      k Environmental Monitoring Section U. Potapovs, VPB, IE R. Lasky, VPB, IE      -
T. Wambach, Project Manager, NRR    [-
P. Shemanski, NRR R. Smeenge, RIII D. Butler, RIII M. Jacobus, Sandia National Labs D. Brosseau, Sandia National Labs D. Jackson, INEL M. Trojovsky, INEL
_ _ _ _ _ _ _ _ _ . . _ - _ __ __ -_-.
}}
}}

Latest revision as of 06:56, 6 May 2021

Forwards Safety Insp Rept 50-255/86-32 on 861208-870113. Eight Significant Deficiencies Noted in Program Implementation.Findings Classified as Potential Enforcement/ Unresolved Items & Ongoing NRC Review Being Performed
ML20211L581
Person / Time
Site: Palisades Entergy icon.png
Issue date: 02/17/1987
From: Harrison J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Buckman F
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML18052A873 List:
References
NUDOCS 8702270158
Download: ML20211L581 (2)


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FEB 17190 Docket No. 50-255 Consumers Power Company ATTN: Dr. F. W. Buckman Vice President Nuclear Operations-212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

This refers to the special safety inspection conducted by Mr. A. S. Gautam and other NRC representatives of this office on December 8, 1986 through January 13, 1987, of activities at the Palisades Nuclear Plant authorized by NRC License No. DPR-20 and to the discussion of our findings with Mr. K. E. Osborne at the conclusion of the inspectio The enclosed copy of our inspection re) ort identifies areas examined during the inspection. Within these areas, t1e inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne Although the inspection determined that you have implemented a program to meet the requirements of 10 CFR 50.49, eight significant deficiencies in the program implementation were observed. These findings are classified as Potential Enforcement / Unresolved Items and an ongoing NRC review is being performed to evaluate the findings in regard to possible future enforcement action In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC-Public Document Roo We will gladly discuss any questions you have concerning this inspection.

Sincerely

'

B702270158 870217 ,

DR ADOCK0500g5 g ,3 . g ,4, g ,' g , } hy ,1 : r,-

,

J. J. Harrison, Chief 4 Engineering Branch Enclosure: Inspection Report --

No. 50-255/86032(DRS) ,

See Attached Distribution 1CS

}EIIISlf RI ' RIII &

r so3 T ur ess H rison Gautam/nma 2/i.js7 *So Westberg An\e An f,go/

..

._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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.

.

Consumers Power Company 2 FEB 171987

-

Distribution cc w/ enclosure:

Mr. Kenneth W. Berry, Director Nuclear Licensing J. F. Firlit, General Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission n Nuclear Facilities and k Environmental Monitoring Section U. Potapovs, VPB, IE R. Lasky, VPB, IE -

T. Wambach, Project Manager, NRR [-

P. Shemanski, NRR R. Smeenge, RIII D. Butler, RIII M. Jacobus, Sandia National Labs D. Brosseau, Sandia National Labs D. Jackson, INEL M. Trojovsky, INEL

_ _ _ _ _ _ _ _ _ . . _ - _ __ __ -_-.