ML18065A404

LER 95-014-00:on 950119,PCP Oil Collection Deficiencies Created by FC-860 Piping Mod.Caused by Inadequate DBD for Sys & Lack of Review by Experienced Fire Protection Personnel.Updated Design Basis documentation.W/960115 Ltr

ML18065A404
Person / Time
Site:	Palisades
Issue date:	01/15/1996
From:	Mathews C, Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-95-014, LER-95-14, NUDOCS 9601220287
Download: ML18065A404 (6)

Text

POWERINli

• . MICHlliAN-S PROliRESS Palisades Nuclear Plant: 27780 Blue Star* Memorial Highway, Covert, Ml 49043 January 15, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT

• LICENSEE EVENT REPORT 95-014 -PRIMARY COOLANT PUMP OIL COLLECTION DEFICIENCIES CREATED BY PIPING MODIFICATION.

Licensee Event Report (LER)95-014 is attached.

This event is reportable to the NRC in accordance with 10CFR50.73(a)(2)(ii)(B).

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector

-Palisades Attachment 9601220287 PDR ADOCK s

-960115 05000255 PDR A CMS' ENERGY COMPANY

• ATTACHMENT CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 LICENSEE EVENT REPORT 95-014 PRIMARY COOLANT PUMP OIL COLLECTION DEFICIENCIES CREA TED BY PIPING MODIFICATION.

4 Pages NRC Form 366 {9-831 U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104 EXPIRES: 8131/85 LICENSEE EVENT REPORT (LERI FACILITY NAME {1) DOCKET NUMBER {21 PAGE (3) Palisades Plant 0 5 0 0 0 2 5 5 OF 0 4 TITLEt41 LICENSEE EVENT REPORT 95-014-PRIMARY COOLANT PUMP OIL COLLECTION DEFICIENCIES CREATED BY FC-860 PIPING MODIFICATION EVENT DATE {51 REPORT DATE (61 OTHER FACILITIES INVOLVED {81 REVISION FACILITY NAMES MONTH DAY YEAR YEAR NUMBER MONTH DAY YEAR N/A .0 5 0 0 0 0 199595-014-0001 5 9 6 N/A 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR t: /Check one or more of the following!

{111 OPERATING MODE {91 N 20.402{b)

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50. 73{a){2Hiiil LICENSEE CONTACT FOR THIS LER {121 AREA CODE 6 6 below and in Text, NRC Form 366A) TELEPHONE NUMBER 7 6 4 8 9 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT {131 CAUSE SYSTEM COMPONENT TURER REPORTABLE TO NPRDS SUPPLEMENTAL REPORT EXPECTED {14) YES Vt yes. complete EXPECTED SUBMISSION DATE) ABSTRACT {Limit to 1400 spaces, I.e., epproxlmately fifteen slngle-spece typewritten Unesl {161 CAUSE SYSTEM COMPONENT TURER MONTH DAY EXPECTED SUBMISSION DATE {151 3 YEAR On January 19, 1995 at 11 :30 am, with the plant operating at full power, it was discovered that the Primary Coolant Pump Oil Collection System was in a degraded condition.

A plant modification during the 1990 Refueling Outage changed the Primary Coolant Pump oil piping in the vicinity of the sight glass drain so that piping extended beyond the coverage areas of the existing collection system which had been installed earlier to meet the requirements of 1 OCFR50, Appendix R. In addition, previously installed spray shields around certain flanged connections and upper oil drain pans were found missing. Compensatory measures of monitoring oil and air temperature were implemented until the necessary oil collection system modifications were completed during the _1995 Outage. The oil collection system is presently in compliance with the design requirements.

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The reportability of the condition was evaluated at the time of discovery.

At that time, it was concluded that a report was not necessary because the prevention of oil fires by the oil collection system was not required to preserve safe shutdown capability.

Since that time, the NRC staff has provided us with additional verbal guidance on Appendix R reportability.

Therefore, we now consider the condition to be reportable.

NRC Form 366A (9*83) FACILITY NAME (1) Palisades Plant EVENT DESCRIPTION LICENSEE EVENT REPORT (LER) TEXT CONTINUATION DOCKET NUMBER (2) LER NUMBER (3) SEQUENTIAL YEAR NUMBER 0 5 0 0 0 2 5 5 9 5 0 1 4 U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104 EXPIRES: 8/31/85 REVISION NUMBER PAGE (4) Q 0 Q 2 OF Q 4 On January 19, 1995 at 11 :30 am, with the plant operating at full power, a fire protection engineer discovered that the Primary Coolant Pump Oil Collection System was in a degraded condition.

He was performing a scheduled review of the adequacy of Primary Coolant Pump oil collection system while reviewing a proposed plant modification to add a new type of oil level monitoring.

Further investigation found that a plant modification installed during the 1 990 Refueling Outage had changed some Primary Coolant Pump oil piping. Piping in the vicinity of the sight glass drain extended beyond the coverage areas of the existing collection system. In addition, for unknown reasons, previously installed oil spray shields around certain flanged connections and upper oil drain pans were found to be missing. Since the Primary Coolant Pumps are required by 1 OCFR50, Appendix R, to have a lube oil collection system that will collect all potential oil leakage from pressurized and unpressurized pipe joints and keep it from contacting hot primary coolant system piping or other ignition sources, the system was judged to no longer meet design requirements.

Compensatory measures were then initiated until permanent design changes could be made. They were: 1 . Increased monitoring of the Primary Coolant Pump upper and lower level lube oil reservoir levels for unexplained significant reductions in oil levels. This monitoring was done once a shift with increased awareness of the operations staff for the potential impact due to improper Primary Coolant Pump oil collection system coverage.

2. Continued monitoring of the containment air temperature with increased awareness of the operations staff that unexplained increases in temperature could be caused by a Primary Coolant Pump lube oil fire. Oil collection system modifications which corrected the deficiencies were completed during the 1995 refueling outage. The oil collection system is presently in compliance with the design requirements.

• • ** *--------**--. --. *-__ _ The reportability of the condition was evaluated at the time of discovery.

At that time, it was concluded that a report was not necessary because the prevention of oil fires by the oil collection system was not required to preserve safe shutdown capability.

Since that time, the NRC staff has provided us with additional verbal guidance on Appendix R reportability.

Therefore, we now consider the condition to be reportable.

NRC Form 366A (9-83) FACILITY NAME (1) Palisades Plant CAUSE OF THE EVENT LICENSEE EVENT REPORT (LERI TEXT CONTINUATION DOCKET NUMBER (2) YEAR 0 5 0 0 0 2 5 5 9 5 LER NUMBER (3) SEQUENTIAL NUMBER 0 1 4 U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104 EXPIRES: 8/31/85 REVISION NUMBER PAGE (4) 0 0 0 3 OF 0 4 The degraded condition of the Primary Coolant Pump lube oil collection system was caused by: 1. Inadequate design basis documentation for this system. 2. Lack of review by experienced Fire Protection personnel for design modifications that were judged by the design engineer as having no impact on Fire Protection Program requirements.

ANALYSIS OF THE EVENT This Primary Coolant Pump lubricating oil system piping was modified in the 1 990 Refueling Outage. This modification (FC-860) replaced the threaded pipe and fittings on the Primary Coolant Pump oil gauge fill, drain, and instrument systems with socket welded components; added or replaced existing gate valves with ball valves and replaced the sight glasses. These changes were made to reduce the potential oil leak locations.

Additional isolation valves were also added that extended the piping beyond the original design envelope.

When this condition was discovered, compensatory additional monitoring was initiated.

Necessary oil collection system modifications were completed during the 1 995 Refueling Outage to reconfigure the oil drip trays. The oil collection system is presently in compliance with 1 OCFR50 Appendix R and design requirements.

SAFETY SIGNIFICANCE Analyses of oil fires in the vicinity of primary coolant pumps,, irrespective of the oil collection systems, have been performed to assure the capability to meet shutdown criteria.

The only reason that oil collection systems are installed at Palisades is because they are explicitly required by 1 OCFR50, Appendix R. Other installed equipment provided adequate early warning to minimize the probability of a fire due to leaking oil.

• During the period between discovery and correction,.

_measures were established to minimize the probability that a Primary Coolant Pump lubricating oil system. leak would go unnoticed.

Those measures included monitoring the oil level every shift and planning to take appropriate actions if a significant leak were identified.

Oil level changes as small as 2 percent or 0.4 gallon were detectable.

Permanent corrections were made to the oil collection system by modifications that were completed during the 1995 Refueling Outage. The oil collection system is presently in compliance with the design requirements.

t . NRC Form 366A (9-83) U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMB NO. 3150-0104 EXPIRES: 8/31/85 *'-LICENSEE EVENT REPORT CLER) TEXT CONTINUATION FACILITY NAME 111 DOCKET NUMBER (21 YEAR Palisades Plant 0 5 0 0 0 2 5 5 9 5 CORRECTIVE ACTIONS The following corrective actions have been completed:

LER NUMBER (3) SEQUENTIAL NUMBER 0 4 REVISION NUMBER PAGE (4) Q Q Q 4 OF Q 4 1. A walkdown of the Primary Coolant Pump oil collection system was performed.

The as-built configuration of the system was defined. 2. The design basis documentation was updated to define the basis for the Primary Coolant Pump lubricating oil collection system. 3. A review to determine possible effects on the Fire Protection Program is now being performed by experienced Fire Protection personnel for all new plant modification packages.

4. The Primary Coolant Pump lubricating oil collection system was modified during the 1 995 Refueling Outage to meet design requirements.