ML18068A300

Responds to NRC 980121 Ltr Re Violations Noted in Insp Rept 50-255/97-13.Corrective Actions:Training on Effects of Stratification in SG on Pcs Temperature Was Provided to Licensed Operators

ML18068A300
Person / Time
Site:	Palisades
Issue date:	02/27/1998
From:	Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-97-13, NUDOCS 9803060419
Download: ML18068A300 (7)

See also: IR 05000255/1997013

Text

.. !' '* . * * Consumers

Energy> A CMS Energy Company February 27, 1998 U.S. Nuclear Regulatory

Commission

ATIN: Document Control Desk Washington, DC 20555 Palisades

Nuclear Plant 27780 Blue Star Memorial Highway Covert, Ml 49043 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT Da11/d llt Rogers General Manager -Plant Operations

REPLY TO NOTICE OF VIOLATION

DESCRIBED

IN INSPECTION

REPORT NO. 50-255/97013

NRC Inspection

Report No. 50-255/97013

dated January 21, 1998, contains a Notice of Violation (NOV) concerning

an inadequate

procedure

which allowed operators

to start a primary coolant pump without meeting Technical

Specification

requirements.

The Consumers

Energy Company reply to the violation

is included in the Attachment

to this letter. The reply to the violation

was requested

to be submitted

within 30 days from the date of the letter transmitting

the violation.

Discussion

with Bruce Burgess (NRC Region Ill) on January 28, 1998, confirmed

that the 30-day requested

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

28, 1998. Consumers

Energy Company agrees with the violation

as written. An additional

concern regarding

the Technical

Specification

aspects of the event and the lack of a questioning

attitude by the operators

was expressed

in the cover letter for the

repor:t. Jha_t concern will be addressed

in more detail in a separate submittal.

9803060419

980227 PDR ADOCK 05000255 G PDR 1111111111111111111111111111111111111111

• &&8E37* l l ' I . I , . ! f

• . * SUMMARY OF COMMITMENTS

This letter contains one commitment.

This commitment

is a restatement

of the . commitment

made previously

in Licensee Event Report 97-011, submitted

on November 11 , 1997. That commitment

is: * System Operating

Procedure

SOP-1 will be revised to clarify requirements

for starting primary coolant pumps when the PCS is solid. This revision will be made prior to the next use of the procedure

for this purpose. David W. Rogers Plant General Manager CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector

-Palisades

Attachment

2

• . -ATTACHMENT

CONSUMERS

ENERGY COMPANY PALISADES

PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION

NO. 50-255/97013-01 (DRP) 4 Pages

• ATTACHMENT

REPLY TO NOTICE OF VIOLATION

NO. 50-255/97013-01 (DRP) NRC NOTICE OF VIOLATION

During an NRG inspection

from October 18 through December 5, 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 Part 50, Appendix 8, 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, or drawings.

Contrary to the above, on October 12, 1997, the operations

shift started the first primary coolant pump, using System Operating

Procedure (SOP)-1, Revision 38, Step 4.3.1.(c)2, a procedure

inappropriate

to the circumstances

in that it allowed using shutdown cooling return temperature (when shutdown cooling is operating), instead of T ccld* which resulted in the operators

exceeding

the Technical

Specifications

T cold primary coolant pump start temperature

limits. This is a Severity Level IV violation (Supplement/).

CONSUMERS

ENERGY COMPANY RESPONSE Consumers

Energy agrees with this violation

as 'written.

Background

On October 12 1997, plant heatup from a short maintenance

outage was in progress.

At approximately

1926 hours0.0223 days <br />0.535 hours <br />0.00318 weeks <br />7.32843e-4 months <br />, with the plant at 250 psia and 130°F, plant prerequisites

and checklists

had been completed

and Primary Coolant Pump (PCP) P-500 was started. Immediately

following

the pump start, the Primary Coolant System (PCS) pressure started to rise. Anticipating

the PCS pressure rise, operators

took manual action and limited the pressure to approximately

280 psia. A Low Temperature

Overpressure

Protection (L TOP) actuation

did not occur since the L TOP setpoint at the prevailing

PCS temperature

was approximately

31 O psia. Because PCS pressure rose to this extent in a solid PCS, it was apparent that heat had been transferred

from the steam generator

secondary

into the PCS, and that Technical

Specification

3.1.1.h(2)

1

• • ATTACHMENT

REPLY TO NOTICE OF VIOLATION

NO. 50-255/97013-01 (DRP) had been violated.

Technical

Specification

3.1.1.h(2)

requires that forced circulation (starting

of the first primary coolant pump) shall not be initiated

unless " ... the steam generator

secondary

temperature

is less than or equal to T cold, to prevent an overpressurization

of the PCS. The magnitude

of the PCS pressure rise following

start of the pump shows that the steam

generator

secondary

bulk fluid temperature

could not have been less than T cold* The steam generators

do not have an installed

temperature

indicator

which can accurately

indicate secondary

fluid temperature.

One method to obtain steam generator

secondary

side temperature

to verify compliance

with Technical

Specifications

is to obtain a contact temperature

reading from a secondary

handhole cover. While normally adequate, the temperature

provided by this method can differ from the bulk average temperature

if the secondary

side fluid is not adequately

mixed. In this event, the temperature

measurement

obtained by the operators

was not representative

of the bulk temperature

due to stratification.

• A similar limitation

exists in the measurement

of primary coolant temperature

when the PCS is on shutdown cooling. Normal T cold indications

could be slightly higher than the coldest temperature

which may exist in the PCS because shutdown cooling flow does not provide complete mixing in the PCS loops. When primary coolant and shutdown cooling system temperatures

are stable, the shutdown cooling return temperature

is typically

cooler than indicated

primary coolant temperatures.

Use of this temperature

as a lower bound value of T cold is normally viewed as more reliable and conservative

than direct T cold indication.

There are times, however, including

during this event, when shutdown cooling return temperature

is higher than T cold* * Operating

Procedure

SOP-1 does not adequately

account for the temperature

measurement

limitations

inherent in the plant design, can be construed

to permit use of shutdown cooling return temperature

instead ofT cold to verify compliance

with Technical

Specifications.

The inadequacy

of this procedure

was the primary cause for the event. The situation

was aggravated, however, because of inadequate

questioning

by the operating

crew. The crew failed to question the significance

of T cold being lower than the shutdown cooling return temperature, and lower than the steam generator

hand hole cover contacttemperature;

they failed to question the apparent conflict between the procedure's

use of shutdown cooling return temperature

and the specific wording of the Technical

Specifications

restriction

on pump starting;

and they failed to consider 2

CJ * ATTACHMENT

REPLY TO NOTICE OF VIOLATION

NO. 50-255/97013-01 (DRP) uncertainty

that may exist in the steam generator

secondary

fluid temperature

as measured at the handhole cover. This event was reported to the NRC in Licensee Event Report 97-011, dated November 11, 1997. Reasons for Violation

The root causes of this violation

are as follows. 1. System Operating

Procedure

SOP-1 was inadequate.

The procedure

did not adequately

account for the temperature

measurement

limitations

inherent in the plant design, and can be construed

to permit use of shutdown cooling return temperature

instead of T cold to verify compliance

with Technical

Specifications.

2. Inadequate

questioning

by the operating

crew contributed

to the event. The crew failed to challenge

the apparent inconsistencies

between the procedure

and Techni.cal

Specifications, and failed to question the accuracy of their temperature

indications.

Corrective

Action Taken and Results Achieved The following

corrective

actions have been taken: 1. The Operations

Superintendent

conducted

a critique of this event with licensed operators

involved.

The emphasis was on compliance

with Technical

Specifications

and making conservative

decisions

with respect to Technical

Specification

limits. * 2. Training on the effects of stratification

in the steam generators

on PCS temperature

was provided to licensed operators.

This included the effects when the PCPs are started and also the effects when the steam generators

are placed on recirculation

or bubbled with Nitrogen.

3. The Operations

Superintendent

discussed

this event with the operating

crews from the standpoint

of making conservative

decisions

when 3

.. ,,. * ATTACHMENT

REPLY TO NOTICE OF VIOLATION

NO. 50-255/97013-01 (DRP) operating

the Plant with respect to Technical

Specification

limits or * procedural

limits. This included lessons learned and advocacy and questioning

attitude by all members of the operating

shift. These actions have raised the sensitivity

of the operating

staff to the need for conservative

decisions

and questioning

of apparent procedure

inconsistencies.

In addition:

4. Strategies

for primary coolant pump starting have been reviewed to identify necessary

procedure

clarifications.

Corrective

Actions Remaining

to Avoid Further Violations

System Operating

Procedure

SOP-1 will be revised to clarify requirements

for starting primary coolant pumps when the PCS is solid. This revision will be made prior to the next use of the procedure

for this purpose. Date Full Compliance

Will Be Achieved Full compliance

will be achieved when System Operating

Procedure

SOP-1 is revised to provide better guidance for starting primary coolant pumps, 4