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{{#Wiki_filter: | {{#Wiki_filter:llRC-- U.S. llUCLIAll lllQULA TOllY CQllmtt9!0fl | ||
11'1 * 'ACILITY NAttt 111 PALISADES PLANT TITLI I., INADEQUATE PROCEDURE RESULTS IN VALVE TESTING DURING PROHIBITED CONDITIONS IYINT DATI Ill 111 llll'OllT OATI 171 OTMlll 'ACILITIU -OLVID *1 NA.MU N/A* | ~11 | ||
-of IN '911-.,.J 1111 | ~VIO Olle llO. J1111-01CW IXPlllll: 11'1 | ||
"°"'" I *.ac.uucn | * LICENSEE EVENT. RE~'<-.~RT (LERt | ||
- | 'ACILITY NAttt 111 PALISADES PLANT TITLI I., | ||
INADEQUATE PROCEDURE RESULTS IN VALVE TESTING DURING PROHIBITED CONDITIONS IYINT DATI Ill LlllN~lll 111 llll'OllT OATI 171 OTMlll 'ACILITIU -OLVID *1 | |||
-I0.-111121 | 'ACl~ITY NA.MU OOCKIT NUlllllllll N/A* 0151010101 I I o I 3 oI ~ s s s I s- o I ol s- o I 1 o 12 oj 6 sI 9 N/A DnllATINO TMll lllPOllT 11.-ITTID PUlllUAlllT TD THI lllQUlllllllNTI O' 10 C,11 §:.IC'lool'.,..."' - of IN '911-.,.J 1111 N :1111.*clit | ||
-I0.7111111211"1 | "°"'" I llllDDI 111 | ||
*.ac.uucn - | |||
-*,71191111ft11111AI | 20.a111 to.11111111111w1 | ||
- | *.nc.11111w1 | ||
* MONTH OAY t'l YH (If .............. | - - | ||
IXHCTID IUlllllfSION DA Tl/ I I I On .March 4, 1988 during a review of Technical Specification (TS) Surveillance Test Q0-5, ;'Valve Test Procedure", the stroking of the service water containment isolation valves CV-0824 and CV-0847 [BI;ISV] for the.containment air coolers [BK;CLK] was discovered to have occurred during prohibited conditions. | **1i1111 | ||
valves are containment isolation valves and will isolate if a large break of the service water line occurs containment. | * i-- | ||
However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air The stroking of these valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two components to be .inoperable, but cycling of these valves would render all three containment air coolers inoperable. | a.m~L . l I0I0 - *.ac.1111111 - I0.-111121 - I0.7111111211"1 OTHlll IS-"'1 ;,, AbtOwt | ||
During the same review, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV] in both TS Surveillance Tests *Q0-1 and Q0-5. These occurrences have been attributed to procedure deficiencies resulting from inadequate procedure development and review. The administrative controls for the review of procedures have been strengthened. | .,_-_ ,,. r.. r. NlfC f t - | ||
A review of other TS tests to determine if similar conditions existed did not identify other tests where conditions outside TS were introduced by test performance. | - | ||
LER 88005-0J | ,_K I0.7Sllll21111 - *,71191111ft11111AI .-.J NAMI | ||
- I0.7111111211MI I0.7:111112111HI LICIHAI CONTACT ,011 THll Liii 1121 I0.71111111fwllllll I0.7Jlloll211sl C S Kozup, Technical Engineer, Palisades "'"" COOi 61116116141 18191113 COMl'LITI ONI LINI .,011 IACM COWQNINT 'AILUlll DllClllllO IN TMll lllflOllT 1111 CAUll SYITIM COMl'ONINT I I .I I I I No I I I .I I I I I I I I I I I I I I I I I I | |||
Bf.II 185 FACILITY NAME 111. DOCKET NUM9ER 121 LER NUMllER 181 PALISADES PLANT TEXT l/f men - | * MONTH OAY V~All t'l YH (If .............. IXHCTID IUlllllfSION DA Tl/ I I I On .March 4, 1988 during a review of Technical Specification (TS) | ||
-<<ldltiotwl NlfC Fann lliu'111171 Description | Surveillance Test Q0-5, ;'Valve Test Procedure", the stroking of the service water containment isolation valves CV-0824 and CV-0847 [BI;ISV] | ||
These valves are containment isolation valves and will isolate if a large break of the service .water line occurs inside containment. | for the.containment air coolers [BK;CLK] was discovered to have occurred during prohibited conditions. Th~se valves are containment isolation valves and will isolate if a large break of the service water line occurs in~ide containment. However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air coolers~ The stroking of these valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two components to be .inoperable, but cycling of these valves would render all three containment air coolers inoperable. During the same review, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV] in both TS Surveillance Tests | ||
However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air coolers. The stroking of thes.e valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two *components to be inoperable, but cycling of these valves would render all three containment air coolers inoperable. | *Q0-1 and Q0-5. | ||
During the same revi.ew, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV]. | These occurrences have been attributed to procedure deficiencies resulting from inadequate procedure development and review. The administrative controls for the review of procedures have been strengthened. A review of other TS tests to determine if similar conditions existed did not identify other tests where conditions outside TS were introduced by test performance. | ||
During the performance of Q0-5, CV-1359 is stroked from the C.ontrol Room [NA]. In order to perform this stroking without disrupting the service water flow to secondary side of the Plant, the manual bypass valve MV-SWlOl [KG;V] is opened. .CV-1359 receives a close signal whenever the safety injection system actuates in order to assure adequate cooling flow to the engineered safety equipment. | LER 88005-0J | ||
The opening of Mv-SWlOl defeats the design feature of CV-1359 to isolate the non-critical service water loads in an accident. | *:J | ||
The opening of MV-SWlOl is* conducted by an auxiliary operator who remains at the valve until CV-1359 is stroked and then closes the bypass valve. The total evolution of opening the manual _ valve, stroking the control valve and reopening the manual valve generally is accomplished within approximately ten minutes. Further engineering review of TS Surveillance Procedures associated with non-critical service water system [KG] isolation, identified that manual bypass MV-SWlOl was opened while CV-1359 is stroked during performance of Surveillance Test Q0-1, "Safety Injection System". A review of surveillance test schedules identified that Q0-1 was to be performed twice prior to plant conditions that would allow opening of MV-SWlOl in accordance with TS 3.4.1. Therefore, a TS interpretation or surveillance test exemption was deemed necessary. | |||
Operation of isolation valve CV-1359 is controlled by TS 3.4.l'which requires service water pump valves, piping and interlocks to be operable. | NAC Form 311A U.*. NUCLEAR IUGULATORY COMMISllON 19-831 LICENSEE EVENT REPORT (LERI TEXT CONTINUATION APPROVED OMil NO. 3150~11>' | ||
TS 3.4.2 allows one component associated with containment cooling to be inoperable provided corresponding redundant components are tested. However, the non-critical service water header isolation valve CV-1359 can be assumed to have no redundant component since there is only one isolation valve. An interpretation of TS 3.4 was submitted to the NRC on April 6, 1988. This interpretation noted the factors listed above, and that if service water flow was partially diverted due to failure of CV-1359 to close, the critical component cooling function would not be lost as long as all <9-8 | . '" EXPIRES:. Bf.II 185 FACILITY NAME 111. DOCKET NUM9ER 121 | ||
NAC Form JlaA | '\ LER NUMllER 181 PALISADES PLANT TEXT l/f men - ii~. - <<ldltiotwl NlfC Fann lliu'111171 Description On March 4, 1988 during a review of Technical Specification (TS) | ||
llEGl'! | Surveillance Test Q0-5, "Valve Test Procedure", the stroking of the service water containment isolation valves CV-0824 and CV-0847 [BI;ISV] | ||
COMMIDION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEC | for the containment air coolers [BK;CLK] was discovered to have occurred during prohibited conditions. These valves are containment isolation valves and will isolate if a large break of the service .water line occurs inside containment. However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air coolers. The stroking of thes.e valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two | ||
'**'J. | *components to be inoperable, but cycling of these valves would render all three containment air coolers inoperable. | ||
EXPIRES: 8/31,, .l. fACILITY NAMI C1I DOCKET NU .. 111 121 Liii Ill 'AOI 131 PALISADES PL.ANT o | During the same revi.ew, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV]. During the performance of Q0-5, CV-1359 is stroked from the C.ontrol Room [NA]. | ||
Subsequently, provisions were made to assure an auxiliary operator remain in the vicinity of MV-SWlOl during the surveillance test. Additional provisions were emplaced such that prior to test performance, both diesel generators would be verified as operable via a status board check and idle*service water pump(s) would be verified operable via a test starting. | In order to perform this stroking without disrupting the service water flow to secondary side of the Plant, the manual bypass valve MV-SWlOl | ||
On*May 6, 1988 the NRC documented their acceptance of this interpretation with the temporary provisions. | [KG;V] is opened. .CV-1359 receives a close signal whenever the safety injection system actuates in order to assure adequate cooling flow to the engineered safety equipment. The opening of Mv-SWlOl defeats the design feature of CV-1359 to isolate the non-critical service water loads in an accident. The opening of MV-SWlOl is* conducted by an auxiliary operator who remains at the valve until CV-1359 is stroked and then closes the bypass valve. The total evolution of opening the manual _ | ||
This letter further noted CP's intent to modify test circuitry of the safety injection system to block the stroking of CV-1359. This modification was completed during the recent refueling outage. 7 Cause Of The Event The cause of the procedural inadequacies of Q0-1 and Q0-5 were the result of inadequate procedure development and review. The present administrative controls for procedure reviews do not assign responsibility to ensure the TS requirements are properly addressed. | valve, stroking the control valve and reopening the manual valve generally is accomplished within approximately ten minutes. | ||
Presently, Administrative Procedure 9.21, "Technical Specification Surveillance Procedure Development" requires the technical reviewer to ensure that and limitations are adequate and that they recognize limiting conditions of operation entered during the conduct of the test or which must be addressed if equipment is determined to be inoperable". | Further engineering review of TS Surveillance Procedures associated with non-critical service water system [KG] isolation, identified that manual bypass MV-SWlOl was opened while CV-1359 is stroked during performance of Surveillance Test Q0-1, "Safety Injection System". A review of surveillance test schedules identified that Q0-1 was to be performed twice prior to plant conditions that would allow opening of MV-SWlOl in accordance with TS 3.4.1. Therefore, a TS interpretation or surveillance test exemption was deemed necessary. Operation of isolation valve CV-1359 is controlled by TS 3.4.l'which requires service water pump valves, piping and interlocks to be operable. TS 3.4.2 allows one component associated with containment cooling to be inoperable provided corresponding redundant components are tested. | ||
However, the technical reviewer is often only cognizant of several of the systems on the test and not all of them. For tests which involve Operations during the performance of the test an review is required, however, no guidance was given on how to perform an Operations. | However, the non-critical service water header isolation valve CV-1359 can be assumed to have no redundant component since there is only one isolation valve. | ||
review. Corrective Action Administrative Procedure 9.21 has been revised to include guidance on how to perform an Operations review. As part of the Operations review, TS requirements will be reviewed to ensure they are adequately addressed during the performance of the TS test. In addition. | An interpretation of TS 3.4 was submitted to the NRC on April 6, 1988. | ||
to the TS interpretation received in regard to the performance of Surveillance Test Q0-1 and the modification to block the stroking of CV-1359 during a simulated safety injection system actuation signal, the requirement to stroke time CV-1359 was added to Q0-6, "Cold Shutdown Valve Test Procedure" which is conducted in the cold shutdown condition. | This interpretation noted the factors listed above, and that if service water flow was partially diverted due to failure of CV-1359 to close, the critical component cooling function would not be lost as long as all ) | ||
For Q0-5, the test methodology was revised to also place the stroking of CV-0824, GV-0847 and CV-1359 into Surveillance Test Q0-6. A review of other TS tests was conducted to determine if similar conditions existed. This review revealed no other tests where _ conditions outside TS were introduced by test p*erformance. | Nl=IC FORf..' 36EiA 31 | ||
During this review it was noted that several surveillance tests required N"C FO"'-' l&eA 19.SJI LER 88005-01 NAC Form 311.A i9-ll)l LICENSEE EVENT REPORT (LERI TEXT CONTINUATION | <9-8 LER 88005-0 l | ||
Procedural revisions to include these enhancements have been completed. | |||
NAC Form JlaA U.I. NUC~EAll llEGl'! *~TOillY COMMIDION 19.S*I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEC Oro~ '**'J. l150~1°' | |||
The cycling interval .takes a maximum of five minutes to complete and is accomplished by a _Control Room operator operating t.he valves from the Control Room. Th,e limiting accident would be a LOCA coincident with a loss of offsite power which has a probability of occurring at approximately 3.0 E- | EXPIRES: 8/31,, .l. | ||
The auxiliary operator opens the bypass valve, the control operator cycles CV-1359 then the auxiliary operator closed the bypass valve. *The limiting condition would be a LOCA as above with the containment air coolers receiving less than design flow due to the bypass valve open. However, containment pre.ssure would be controlled within the accident limits by the containment spray system until full service water flow could be restored. | fACILITY NAMI C1I DOCKET NU. .111 121 Liii N~lll Ill 'AOI 131 PALISADES PL.ANT o 1s I o I o I o I 21 5 15 81 8 - o*1 o Is - o I i oI 3 oF oI h TEXT I/I mare-ii ,..,.,;.d, - - N M : Fomt.-.'111171 three service water pumps were operable; ie, the third service water pump is the functionally redundant component. Subsequently, provisions were made to assure an auxiliary operator remain in the vicinity of MV-SWlOl during the surveillance test. Additional provisions were emplaced such that prior to test performance, both diesel generators would be verified as operable via a status board check and idle*service water pump(s) would be verified operable via a test starting. On*May 6, 1988 the NRC documented their acceptance of this interpretation with the temporary provisions. This letter further noted CP's intent to modify test circuitry of the safety injection system to block the stroking of CV-1359. This modification was completed during the recent refueling outage. | ||
7 Cause Of The Event The cause of the procedural inadequacies of Q0-1 and Q0-5 were the result of inadequate procedure development and review. The present administrative controls for procedure reviews do not assign responsibility to ensure the TS requirements are properly addressed. | |||
Presently, Administrative Procedure 9.21, "Technical Specification Surveillance Procedure Development" requires the technical reviewer to ensure that '~re~autions and limitations are adequate and that they recognize limiting conditions of operation entered during the conduct of the test or which must be addressed if equipment is determined to be inoperable". However, the technical reviewer is often only cognizant of several of the systems on the test and not all of them. For tests which involve Operations during the performance of the test an Opera~ions review is required, however, no guidance was given on how to perform an Operations. review. | |||
Corrective Action Administrative Procedure 9.21 has been revised to include guidance on how to perform an Operations review. As part of the Operations review, TS requirements will be reviewed to ensure they are adequately addressed during the performance of the TS test. | |||
In addition. to the TS interpretation received in regard to the performance of Surveillance Test Q0-1 and the modification to block the stroking of CV-1359 during a simulated safety injection system actuation signal, the requirement to stroke time CV-1359 was added to Q0-6, "Cold Shutdown Valve Test Procedure" which is conducted in the cold shutdown condition. For Q0-5, the test methodology was revised to also place the stroking of CV-0824, GV-0847 and CV-1359 into Surveillance Test Q0-6. | |||
A review of other TS tests was conducted to determine if similar conditions existed. This review revealed no other tests where _ | |||
conditions outside TS were introduced by test p*erformance. During this review it was noted that several surveillance tests required enhance~ent N"C FO"'-' l&eA 19.SJI LER 88005-01 | |||
'! | |||
! | |||
NAC Form 311.A U.I. llUCLEAlll lllEGULATOlllY COMMllllOH i9-ll)l LICENSEE EVENT REPORT (LERI TEXT CONTINUATION AjlpROVED OMll 1'10. l150-41ci' | |||
. EXPIRES: 8/31 /15 PACILITY NAMI 111 DOCKET 1'1U. .Ell 121 Liii N~lll 111 'AO I l PALISADES PLANT TEXT llf,,.. _ i t _ _, - - | |||
* N l l C Forrrt.-..'111171 0 1s I 0 I 0 I 0 I 215 15 . s, 8 - 0 I0 I 5- 0 11 0 14 OF 0 Ih to.identify limiting conditions of operation entered during test pert'ormance. Procedural revisions to include these enhancements have been completed. - | |||
Analysis Of The Event The closure of CV-0824 and CV-0847 would render all three containment air cooler fans inoperable due to the loss of service water until the valves are reopened. The cycling interval .takes a maximum of five minutes to complete and is accomplished by a _Control Room operator operating t.he valves from the Control Room. Th,e limiting accident would be a LOCA coincident with a loss of offsite power which has a probability of occurring at approximately 3.0 E-8 events per hour. For the LOCA with a loss of offsite power, the containment pressure would be controlled within the accident limits by the containment spray system. | |||
The cycling O'f CV-1359 resulted in the opening of MV-SW101 for a maximum of 15 minutes and is accomplished by an auxiliary operator in conjunction with a Control Room operator. The auxiliary operator opens the bypass valve, the control operator cycles CV-1359 then the auxiliary operator closed the bypass valve. *The limiting condition would be a LOCA as above with the containment air coolers receiving less than design flow due to the bypass valve open. However, containment pre.ssure would be controlled within the accident limits by the containment spray system until full service water flow could be restored. | |||
No adverse risk to the safety of the public resulted due to the low probability of occurrence of an accident coincident with the short time which the above valves were inoperable. | No adverse risk to the safety of the public resulted due to the low probability of occurrence of an accident coincident with the short time which the above valves were inoperable. | ||
Additional Information Two related reportable events involving inadequate reviews of TS tests were: Licensee Event Report 83-039 H | Additional Information Two related reportable events involving inadequate reviews of TS tests were: | ||
Licensee Event Report 83-039 H Recombiners Tested Simultaneously 2 | |||
' l'fif POWERING MICHIGAN'S PROGRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 February 7, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR | Licensee Event *Report 86-021 Inoperable Containment Building Water Level Instrument NlllC FOlllM 368A 19-1131 T_!'.:R 88005-01 | ||
event is repo"rtable to the NRC per 10CFR50.73(e)(2)(i). | ~: | ||
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector | ~U-i.* ' l'fif Power | ||
-Palisades Attachment}} | ,.~~/ | ||
'~:.;1. POWERING MICHIGAN'S PROGRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 February 7, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - | |||
LICENSEE EVENT REPORT 88-005 INADEQUATE PROCEDURE RESULTS IN VALVE TESTING DURING ~ROHIBITED CONDITIONS Licensee Event Report (LER) 88-005-01 (Inadequate Procedure Results in Valve Testing During Prohibited CondHions) is attached. ~his event is repo"rtable to the NRC per 10CFR50.73(e)(2)(i). | |||
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0289-0037-~In2}} | |||
Revision as of 09:24, 20 October 2019
| ML18348A902 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/07/1989 |
| From: | Johnson B Consumers Power Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| LER 1988-005-01 | |
| Download: ML18348A902 (5) | |
Text
llRC-- U.S. llUCLIAll lllQULA TOllY CQllmtt9!0fl
~11
~VIO Olle llO. J1111-01CW IXPlllll: 11'1
- LICENSEE EVENT. RE~'<-.~RT (LERt
'ACILITY NAttt 111 PALISADES PLANT TITLI I.,
INADEQUATE PROCEDURE RESULTS IN VALVE TESTING DURING PROHIBITED CONDITIONS IYINT DATI Ill LlllN~lll 111 llll'OllT OATI 171 OTMlll 'ACILITIU -OLVID *1
'ACl~ITY NA.MU OOCKIT NUlllllllll N/A* 0151010101 I I o I 3 oI ~ s s s I s- o I ol s- o I 1 o 12 oj 6 sI 9 N/A DnllATINO TMll lllPOllT 11.-ITTID PUlllUAlllT TD THI lllQUlllllllNTI O' 10 C,11 §:.IC'lool'.,..."' - of IN '911-.,.J 1111 N :1111.*clit
"°"'" I llllDDI 111
- .ac.uucn -
20.a111 to.11111111111w1
- .nc.11111w1
- -
- 1i1111
- i--
a.m~L . l I0I0 - *.ac.1111111 - I0.-111121 - I0.7111111211"1 OTHlll IS-"'1 ;,, AbtOwt
.,_-_ ,,. r.. r. NlfC f t -
-
,_K I0.7Sllll21111 - *,71191111ft11111AI .-.J NAMI
- I0.7111111211MI I0.7:111112111HI LICIHAI CONTACT ,011 THll Liii 1121 I0.71111111fwllllll I0.7Jlloll211sl C S Kozup, Technical Engineer, Palisades "'"" COOi 61116116141 18191113 COMl'LITI ONI LINI .,011 IACM COWQNINT 'AILUlll DllClllllO IN TMll lllflOllT 1111 CAUll SYITIM COMl'ONINT I I .I I I I No I I I .I I I I I I I I I I I I I I I I I I
- MONTH OAY V~All t'l YH (If .............. IXHCTID IUlllllfSION DA Tl/ I I I On .March 4, 1988 during a review of Technical Specification (TS)
Surveillance Test Q0-5, ;'Valve Test Procedure", the stroking of the service water containment isolation valves CV-0824 and CV-0847 [BI;ISV]
for the.containment air coolers [BK;CLK] was discovered to have occurred during prohibited conditions. Th~se valves are containment isolation valves and will isolate if a large break of the service water line occurs in~ide containment. However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air coolers~ The stroking of these valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two components to be .inoperable, but cycling of these valves would render all three containment air coolers inoperable. During the same review, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV] in both TS Surveillance Tests
- Q0-1 and Q0-5.
These occurrences have been attributed to procedure deficiencies resulting from inadequate procedure development and review. The administrative controls for the review of procedures have been strengthened. A review of other TS tests to determine if similar conditions existed did not identify other tests where conditions outside TS were introduced by test performance.
LER 88005-0J
- J
NAC Form 311A U.*. NUCLEAR IUGULATORY COMMISllON 19-831 LICENSEE EVENT REPORT (LERI TEXT CONTINUATION APPROVED OMil NO. 3150~11>'
. '" EXPIRES:. Bf.II 185 FACILITY NAME 111. DOCKET NUM9ER 121
'\ LER NUMllER 181 PALISADES PLANT TEXT l/f men - ii~. - <<ldltiotwl NlfC Fann lliu'111171 Description On March 4, 1988 during a review of Technical Specification (TS)
Surveillance Test Q0-5, "Valve Test Procedure", the stroking of the service water containment isolation valves CV-0824 and CV-0847 [BI;ISV]
for the containment air coolers [BK;CLK] was discovered to have occurred during prohibited conditions. These valves are containment isolation valves and will isolate if a large break of the service .water line occurs inside containment. However, with a safety injection signal or a containment isolation signal, these valves remain open to supply service water to the containment air coolers. The stroking of thes.e valves momentarily defeats the design safety function of these valves; ie, remain open and supply service water. TS 3.4.2 allows a total of two
- components to be inoperable, but cycling of these valves would render all three containment air coolers inoperable.
During the same revi.ew, a similar problem was noted with the stroking of the non-critical service water isolation valve CV-1359 [KG;ISV]. During the performance of Q0-5, CV-1359 is stroked from the C.ontrol Room [NA].
In order to perform this stroking without disrupting the service water flow to secondary side of the Plant, the manual bypass valve MV-SWlOl
[KG;V] is opened. .CV-1359 receives a close signal whenever the safety injection system actuates in order to assure adequate cooling flow to the engineered safety equipment. The opening of Mv-SWlOl defeats the design feature of CV-1359 to isolate the non-critical service water loads in an accident. The opening of MV-SWlOl is* conducted by an auxiliary operator who remains at the valve until CV-1359 is stroked and then closes the bypass valve. The total evolution of opening the manual _
valve, stroking the control valve and reopening the manual valve generally is accomplished within approximately ten minutes.
Further engineering review of TS Surveillance Procedures associated with non-critical service water system [KG] isolation, identified that manual bypass MV-SWlOl was opened while CV-1359 is stroked during performance of Surveillance Test Q0-1, "Safety Injection System". A review of surveillance test schedules identified that Q0-1 was to be performed twice prior to plant conditions that would allow opening of MV-SWlOl in accordance with TS 3.4.1. Therefore, a TS interpretation or surveillance test exemption was deemed necessary. Operation of isolation valve CV-1359 is controlled by TS 3.4.l'which requires service water pump valves, piping and interlocks to be operable. TS 3.4.2 allows one component associated with containment cooling to be inoperable provided corresponding redundant components are tested.
However, the non-critical service water header isolation valve CV-1359 can be assumed to have no redundant component since there is only one isolation valve.
An interpretation of TS 3.4 was submitted to the NRC on April 6, 1988.
This interpretation noted the factors listed above, and that if service water flow was partially diverted due to failure of CV-1359 to close, the critical component cooling function would not be lost as long as all )
Nl=IC FORf..' 36EiA 31
<9-8 LER 88005-0 l
NAC Form JlaA U.I. NUC~EAll llEGl'! *~TOillY COMMIDION 19.S*I LICENSEE EVENT REPORT (LER) TEXT CONTINUATION APPROVEC Oro~ '**'J. l150~1°'
EXPIRES: 8/31,, .l.
fACILITY NAMI C1I DOCKET NU. .111 121 Liii N~lll Ill 'AOI 131 PALISADES PL.ANT o 1s I o I o I o I 21 5 15 81 8 - o*1 o Is - o I i oI 3 oF oI h TEXT I/I mare-ii ,..,.,;.d, - - N M : Fomt.-.'111171 three service water pumps were operable; ie, the third service water pump is the functionally redundant component. Subsequently, provisions were made to assure an auxiliary operator remain in the vicinity of MV-SWlOl during the surveillance test. Additional provisions were emplaced such that prior to test performance, both diesel generators would be verified as operable via a status board check and idle*service water pump(s) would be verified operable via a test starting. On*May 6, 1988 the NRC documented their acceptance of this interpretation with the temporary provisions. This letter further noted CP's intent to modify test circuitry of the safety injection system to block the stroking of CV-1359. This modification was completed during the recent refueling outage.
7 Cause Of The Event The cause of the procedural inadequacies of Q0-1 and Q0-5 were the result of inadequate procedure development and review. The present administrative controls for procedure reviews do not assign responsibility to ensure the TS requirements are properly addressed.
Presently, Administrative Procedure 9.21, "Technical Specification Surveillance Procedure Development" requires the technical reviewer to ensure that '~re~autions and limitations are adequate and that they recognize limiting conditions of operation entered during the conduct of the test or which must be addressed if equipment is determined to be inoperable". However, the technical reviewer is often only cognizant of several of the systems on the test and not all of them. For tests which involve Operations during the performance of the test an Opera~ions review is required, however, no guidance was given on how to perform an Operations. review.
Corrective Action Administrative Procedure 9.21 has been revised to include guidance on how to perform an Operations review. As part of the Operations review, TS requirements will be reviewed to ensure they are adequately addressed during the performance of the TS test.
In addition. to the TS interpretation received in regard to the performance of Surveillance Test Q0-1 and the modification to block the stroking of CV-1359 during a simulated safety injection system actuation signal, the requirement to stroke time CV-1359 was added to Q0-6, "Cold Shutdown Valve Test Procedure" which is conducted in the cold shutdown condition. For Q0-5, the test methodology was revised to also place the stroking of CV-0824, GV-0847 and CV-1359 into Surveillance Test Q0-6.
A review of other TS tests was conducted to determine if similar conditions existed. This review revealed no other tests where _
conditions outside TS were introduced by test p*erformance. During this review it was noted that several surveillance tests required enhance~ent N"C FO"'-' l&eA 19.SJI LER 88005-01
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NAC Form 311.A U.I. llUCLEAlll lllEGULATOlllY COMMllllOH i9-ll)l LICENSEE EVENT REPORT (LERI TEXT CONTINUATION AjlpROVED OMll 1'10. l150-41ci'
. EXPIRES: 8/31 /15 PACILITY NAMI 111 DOCKET 1'1U. .Ell 121 Liii N~lll 111 'AO I l PALISADES PLANT TEXT llf,,.. _ i t _ _, - -
- N l l C Forrrt.-..'111171 0 1s I 0 I 0 I 0 I 215 15 . s, 8 - 0 I0 I 5- 0 11 0 14 OF 0 Ih to.identify limiting conditions of operation entered during test pert'ormance. Procedural revisions to include these enhancements have been completed. -
Analysis Of The Event The closure of CV-0824 and CV-0847 would render all three containment air cooler fans inoperable due to the loss of service water until the valves are reopened. The cycling interval .takes a maximum of five minutes to complete and is accomplished by a _Control Room operator operating t.he valves from the Control Room. Th,e limiting accident would be a LOCA coincident with a loss of offsite power which has a probability of occurring at approximately 3.0 E-8 events per hour. For the LOCA with a loss of offsite power, the containment pressure would be controlled within the accident limits by the containment spray system.
The cycling O'f CV-1359 resulted in the opening of MV-SW101 for a maximum of 15 minutes and is accomplished by an auxiliary operator in conjunction with a Control Room operator. The auxiliary operator opens the bypass valve, the control operator cycles CV-1359 then the auxiliary operator closed the bypass valve. *The limiting condition would be a LOCA as above with the containment air coolers receiving less than design flow due to the bypass valve open. However, containment pre.ssure would be controlled within the accident limits by the containment spray system until full service water flow could be restored.
No adverse risk to the safety of the public resulted due to the low probability of occurrence of an accident coincident with the short time which the above valves were inoperable.
Additional Information Two related reportable events involving inadequate reviews of TS tests were:
Licensee Event Report 83-039 H Recombiners Tested Simultaneously 2
Licensee Event *Report 86-021 Inoperable Containment Building Water Level Instrument NlllC FOlllM 368A 19-1131 T_!'.:R 88005-01
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~U-i.* ' l'fif Power
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'~:.;1. POWERING MICHIGAN'S PROGRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 February 7, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
LICENSEE EVENT REPORT 88-005 INADEQUATE PROCEDURE RESULTS IN VALVE TESTING DURING ~ROHIBITED CONDITIONS Licensee Event Report (LER) 88-005-01 (Inadequate Procedure Results in Valve Testing During Prohibited CondHions) is attached. ~his event is repo"rtable to the NRC per 10CFR50.73(e)(2)(i).
Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC0289-0037-~In2