ML18058A334

LER 92-018-00:on 920305,determined That Containment Electrical Penetration Connectors Were Not Qualified W/ 10CFR50.49.Caused by Lack of Adequate Technical Guidance. Subj Connectors replaced.W/920403 Ltr

ML18058A334
Person / Time
Site:	Palisades
Issue date:	04/03/1992
From:	Hillman C, Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-92-018, LER-92-18, NUDOCS 9204130203
Download: ML18058A334 (5)

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consumers Power GB Slade General Manager

. POWERiNii

. llAICRlliAN'S PROliRE.55 Palisades Nuclear Plant: 27780 Blue Star Memorial Highway; Covert, Ml 49043 April 3, 1992 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 ~ LICENSE DPR PALISADES PLANT -

LICENSEE EVENT REPORT 92~018 - LACK OF ENVIRONMENTAL QUALIFICATION FOR CONTAINMENT ELECTRiCAL PENETRATIONS FOR THE SAFETY INJECTION TANKS ELECTRICAL CONTROL SCHEME*

Lice_nsee Event Report (LER)92-018 is attached. This event is reportable to the NRC in accordance with 10CFR50.73(a)(2)(ii)(B) as a*condition outside the design basis of the plant.

~:r~r General Manager

• .CC Administratbr, Region Ill, USNRC

• NRC Resident Inspector - Palisades Attachment

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Palisades Plant o js 10101012 1515 1 OF 014 TITU l'I LACK OF ENVIRONMENTAL QUALIFICATION FOR CONTA;INMENT ELECTRICAL PENETRATIONS FOR THE.SAFETY INJECTION TANKS ELECTRICAL.CONTROL SCHEME IV Ill II N~lll 111 lllP'OllT OATI 171 OTHlll.,ACILITIU IWOLVID Ill NTH YIAR YEAR  ?> HQUINTIAL NUMll"  ::: MVlllON MONTH NUMll" DAV VE R PACl~ITY NAMU DOCICIT NUMIERISI

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. ABSTRACT On March 5, 1992, with the plant shutdown for the r~fueling, it was determined that the containment electrical penetration connectors for the solenoid valves which supply control air to the Safet~ Injection Tanks pre~sure and fill control valves were not environmentally qualified in accordance ~ith 10 CFR 50.49. .

The root cause for this event is the lack of adequate technical guidance and administrative controls for the removal of e~uipment from the envi~ohmental qualification (EQ) list.

Corrective actions for this event include replacing th~ containment electrical*

penetration connectors with environmentally qualified connectors, additional training on EQ prog~am requirements, de~elopmerit of ~n engineering design guide on environmental qualification, and review of equipment removed from the EQ list to assure ad~quate justification for the removal exists.

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-* TDT ,, _ - * ,_. - - /llllC ,.._ -.*111111 EVENT DESCRIPTION On March 5 ~ 1992, with the pl ant in cold shutdown for th.e 1992 refueling outage~ it ~as det~rmined that the containment electrical penetration

• connectors [NH;PEN] for the solenoid valves which supply control air to the Safety Injection Tanks (SITs) pressure and fill control valves [BP;PCV] were not environmentally qualified in accordance with 10 CFR 50.49. *This condition was discovered during an environmental qualification review of the entire ..

• electrical scheme for the SITs pressure and fill control valves~

This event is reportable to the NRC in accordance with 10CFR50. 73 (a)(2}(ii )(B) as a condition outside the design basis of the plant.

CAUSE OF THE EVENT ..

The root cause for this event is the lack of adequate technical guidance and administrative controls for the removal of equipment from the environmental qualificat1on (EQ) list.

• This event does not involve the failure of any equipment important to safety.

ANALYSIS OF THE EVENT Sole~oid val~es SV-0338, SV-0342, SV-0346 and SV-0347 ate used for ~upplying the control air to the four Safety Injection Tanks pressure and fill co~trol valves CV-3018, CV-3042, CV-3046 .and CV-3047, respectively. The solenoid

• valve~ are normally energized during plant operation which permits the pressure transmitters to control the valve position. SIT pressure is monitored in the SIT discharge line between the inboard and outboard check valves. *1f the SIT pressure exceeds the pressure transmitter set-point, which may occur due to leakage through the primary coolant system (PCS) check valve, the pressure transmitters .PT-0338, PT-0342, PT~0346, and PT-0347 signal* the control valves to open to allow drainage of the Sil to the radioactive waste treatment system, to reduce the SIT pressure.

lhe subje~t solenoid valves are required to close on a safety inj~ction ~ignal (SIS) *in order to close the associated control valves and thereby prevent the*

loss of fluid from the SITs.

• The ~olenoid valves are designed to

~utomatically de-energize upon receipt of an SIS which overrides the automatic pressure control loop signal .and keeps the control valves closed.

The solenoid valves are located inside containment.which is considered a harsh

. environment during a loss* of coolant accident ~(LOCA). Since the pressure and fill control valves (and ultimately the solenoid valves whi~h control the supply air to these valves) are required to operate during a LOCA, the solenoid valves are required to be environmentally qualified in accordance with 10 CFR 50.49.

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• Palisades Plant T111T1*-9!!911 ....... _ _ _ /lll/IC,._ . . .111171 Solenoid valves SV-0338, SV-0342, SV-0346 and SV-034i were on. the origirial environmental qualification submittal of 1980 which stated they could not be qualified for the harsh environ~ent and would be replaced with qualified solenoids. The solenoid.valves were replaced about September 1981. It is unknown exactly when the solenoid ~alves were r~moved from the EQ list; however, their removal was-based on the fact that the valves fail to their safe position and that they receive a Safety Injection Signal to close prior to experiencing a "significant harsh environment." It.has since been .

. determined that this basis is not technically adequate to justify the removal of safety related equipment from the EQ list, although it may ~rovide an adequate basis for qualifying the equipment for less than the full duration of*.

the accident.

Although the solenoid valves are qualified, the penetration conn~~tors were found to be environmentally unqualified which could cause their electrical circuits tci fail, thereby preventing them from performing their safety function. The lack of environmental qualification of the penet'ration connectors (EZ221~16 and EZ221~17) was identified during the review 6f the solenoid valves instrument loops to assure adequate environmental qualification.

• During the time the solenoid valves were not -0n the EQ list, there were general modifications to replace many environmentally non-tjualified electrical containment penetration connectors with environmentally qualified connectors.

Since the SIT pressure* and fill control va1ve solen6ids were not on the EQ list, and no other environmentally qualified equipment utilized their*

penetration connector~, there ~ppeared to be nb justification tb replace the connectors, and,_ therefore, the connectors were not replaced ..

! CORRECTIVE ACTION i

ii Corrective action was imniediately initiated to return the SITs control valves solenoid valves t6 the active EQ list. The qualified life calculati6n for the SITs control valves .solenoid valves was checked to see if the remainthg .

.. qualified life was acceptable. The remaining qualified life is acceptable.

The maintenance retords for the solenoid.valves were reviewed to assure th~

solenoid valves were maintained in accordance .with the qualification requirements. The solenoid valves have been properly mai~tained in accordance.

with environmental qualification requirements.

Based on the remaining qu~lified life and thecadequacy of maintenance, the solenoid valves remain qualified and will. be placed back on the EQ list.

A modification was initiated to replace the electrical penetration connectors during.the 1992 refueling outage:

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.Palisades Plant 01s101010121s 1s 912 _o 1 .~s_o 1 o ~4 0 ,:o 4 TIXTt*--*,.._ __ ,_,..,.,,...."'111 1 Additional corrective actions include trairiing on EQ program requirements for plant and engineeri~g personnel involved tn engineering and*maintenance of electrical equipment environmental qualification, development of an e~gineeririg design gtiide on EQ, and teview of equipment removed from the EQ list to assure adequate justification for the removal exists.

ADDITIONAL INFORMATION Recently submitted licensee event reports ~hich also deal with the ~ubject of lack of environmental qualification include LER 92006, LER 92007~ LER 92012 and LER 92013.