ML18067A709

Forwards Response to Violations Noted in Insp Rept 50-255/97-08.Corrective Actions:Operating Procedures Have Been Revised to Better Define Safety State & Prohibit Operation at Steady State Power Level Greater than Limit

ML18067A709
Person / Time
Site:	Palisades
Issue date:	10/09/1997
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-08, 50-255-97-8, NUDOCS 9710150161
Download: ML18067A709 (6)

See also: IR 05000255/1997008

Text

• Consumers

Ener9i')>

October 9, 1997 U.S. Nuclear Regulatory

Commission

ATIN: Document Control Desk

Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT -=: '3: t5 ... '3J 2290 .-.: .... s: c -5..:

Tlloma* J. Palmluno Site Vice President

REPLY TO NOTICE OF VIOLATION

50-255/97008-01

-PLANT PROCEDURES

ALLOW STEADY STATE POWER LEVEL GREATER THAN LICENSE LIMIT NRC Inspection

Report No. 50-255/97008(DRP)

dated September

5, 1997, contained

a Notice of Violation

for a Severity Level IV violation

concerning

the potential

to exceed the licensed full power limit. Attachment

1 contains our response to the violation.

The response to the violation

was required to be submitted

within 30 days from the date of the letter transmitting

the violation.

Discussion

with Bruce Burgess at Region Ill on September

23, 1997, confirmed

that the 30-day requested

response could be provided within 30 days of receipt of the letter, which was September

11, 1997. '-The inspection

cover letter also noted a continuing

weakness with post maintenance

testing and an example of weak ALARA planning.

These two weaknesses

are being addressed

and status of our efforts in this area will be submitted

in a separate letter. 9710150161 ADOCK PDR 1111111111111111111111111111111111111111

• 18 9 7 11 11 2 *

• • * SUMMARY OF COMMITMENTS

This letter contains no new commitments

and no revisions

to existing commitments. Thomas J. Palmisano

Site Vice President

CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector

-Palisades

Attachment

2

ATTACHMENT

1 CONSUMERS

ENERGY COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

PLANT PROCEDURES

ALLOW STEADY STATE POWER LEVEL GREATER THAN LICENSE LIMIT 3 Pages

NRC VIOLATION

During an NRG inspection

conducted

on May 24 through July 7, 1997, one violation

of NRG requirements

was identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRG Enforcement

Actions," NUREG 1600, the violation

is listed below: 10 CFR 50, Appendix B, Criterion

V, "Instructions, Procedures, and Drawings," requires, in part, that activities

affecting

quality shall be prescribed

by documented

instructions, procedures, or drawings, of a type appropriate

to the circumstances

and shall be accomplished

in accordance

with these instructions, procedures

and drawings.

Palisades

Plant Facility Operating

License, section 2.c.(1), states, in part, that "CPCo is authorized

to operate the facility at steady-state

reactor core power levels not in excess of 2530 megawatts

thermal (100 percent rated power) in accordance

with the conditions

specified

herein." Contrary to the above, on February 7, 1996, the operations

shift conducted

an activity affecting

quality, the delithiation

of the Reactor Coolant System, using General Operating

Procedure (GOP)-12, Revision 12, Section 5. 3. 1 a, a procedure

inappropriate

to the circumstances

in that it allowed plant operators

to operate the plant at 100.99 percent power (2555 megawatts

thermal}, a steady state power level greater than the license limit. ' This is a Severity Level IV violation (Supplement

I) CONSUMERS

ENERGY COMPANY RESPONSE Consumers Energy

agrees that the facts are as stated. General Operating

Procedure (GOP) -12 as written would have allowed plant operators

to operate the plant at a steady state power level greater than the license limit. Uncertainty

analyses combined with follow..:up

ultrasonic

flow measurements, however, reveal that neither the licensing

nor design bases were exceeded throughout

this event. ' BACKGROUND

On February 7, 1996, during a planned delithiation

of the reactor coolant system, a slight increase in the plant power level was observed.

The power level was controlled

and monitored

in compliance

with the existing procedures

and resulted in an indicated

1

plant power level slightly in excess of 100% of licensed power for nine consecutive

hours. Initial investigation

of the involved measurement

uncertainties

led to the event being reported as LER 96-006 on March 11, 1996, as a condition

possibly outside of the design basis and in violation

of a license condition

which requires that the plant not be operated in excess of 2530 Megawatts

thermal (100% rated power levels). Palisades'

procedures

had considered

this license condition

steady state limit to be met if reactor power averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was below 2530 megawatts.

Minor excursions

above 100 percent power were viewed as acceptable

as long as peak power did not exceed 101 percent and the 24-hour average power was less than 2530 megawatts.

The slow power rise during delithiation

was viewed as a transient

condition

not subject to the steady state limit specified

in the license. During a later review of power level records, questions

were raised about whether

averaging

was the appropriate

standard to assure license compliance, and whether measurement

uncertainties

were adequately

considered

in the procedure

limit on peak power. Subsequent

tests and analyses have shown that Palisades

did not exceed the 10 CFR 50.2 design basis and did not exceed 100% power during the period in question.

This conclusion

was reported to the NRC on August 2, 1996, as Supplement

1 to LER 96-006. EVENT ANALYSIS Two separate actions were taken during the investigation

of this event. These actions were: 1. The calorimetric

uncertainty

analysis was redone to more accurately

reflect the calorimetric

uncertainty.

This analysis was rigorously

reviewed by Consumers

Energy Company and an outside contractor

with significant

in uncertainty

analyses.

2. An ultrasonic

flow measurement (UFM) of the feedwater

flow was performed

on May 21-22, 1996 to assess the plant thermal performance.

The UFM provided a more accurate measurement

of feedwater

flow independent

of the installed

feedwater

venturies.

The final results from the calorimetric

uncertainty

analysis showed the uncertainty

to be 1.01 %. Wl:ten this c:;alorimetric

uncertainty

of 1.01 % is added to the maximum power level recorded (100.41%), the resulting

value is within the Palisades

Design Basis value of 102%. It is, therefore, concluded

by this analysis that actual reactor power did not exceed the design basis value throughout

this event. 2

!' ,, i The results of the more accurate UFM revealed that actual power was 2.2% less than indicated

power based on the feedwater

venturies.

The conservative

bias associated

with the venturies

is due primarily

to a conservative

initial venturi calibration

and to venturi fouling. The UFM device is considered

to be more accurate than the venturies

due to rigorous testing by the vendor and the device's independence

from fouling. Using the ultrasonic

flow results, the maximum power level achieved during the event was determined

to be 98.2%. It has, therefore, been concluded

that Palisades'

actual reactor power did not exceed 100% licensed power throughout

the event. REASON FOR THE VIOLATION

• The root cause for the event was that the procedural

guidance for the operators

regarding

compliance

with licensed steady-state

reactor core power levels was not sufficiently

conservative.

CORRECTIVE

STEPS TAKEN AND RESULTS ACHIEVED The following

corrective

actions were accomplished:

Operating

procedures

have been revised to better define *isteady state" and prohibit operation

at a steady state power level greater than the license limit. The calorimetric

uncertainty

analysis was reviewed to verify that it reflected

known uncertainties.

The analysis revealed that Palisades

remained within the established

design basis at all times. A flow test using UFM was performed

on May 21-22, 1996. The results of the flow measurement

revealed that the installed

flow venturies

have a conservative

bias. This resulted in the indicated

reactor power reading higher than the actual power. The measurement

results indicated

that 100% power was not exceeded throughout

the event. CORRECTIVE

STEPS TAKEN TO AVOID FURTHER VIOLATIONS

No additional

actions are required.

DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

was achieved on March 11, 1996, when the appropriate

procedures

were revised. 3