ML18053A467

Provides Info on Changes in Planned Completion Dates or Actions Resulting from Responses to NRC 860521 Confirmatory Action Ltr,Including Matl Condition Task Force & Insp Equipment Issues

ML18053A467
Person / Time
Site:	Palisades
Issue date:	07/29/1988
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CAL, NUDOCS 8808030400
Download: ML18053A467 (17)

Text

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• consumers Power POWEIJINli lllllCHlliAN"S PllOliRESS Ge.neral Offices: 1945 West Parnell R_oad, Jackson, Ml 49201 * (517) 788-0550 July 29, 1988 ri.*

Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

• DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

UPDATE TO ACTION ITEMS SUPPORTING THE MAY 21, 1986 CONFIRMATORY ACTION LETTER On June 24, 1988 a Quarterly Management Update between Consumers Power and the Nuclear Regulatory Commission was held in Gleri Ellyn, IL At this meeting Consumers Power offered to provide information on changes in planned completion dates or actions resulting from our responses to the NRC letter of May 21, 1986 (Consumers Power letters dated July 3, 1986; December 1, 1986; January 28, 1987; September 14, 1987 and October 30, 1987).

This letter provides that information and a completion status of the previously identified action items. The action items identified by Consumers Power have been broken down into*the improvement.program from which they.were initiated. These programs correspond to Plant improvement efforts initiated by Consumers Power and inspections previously conducted by the Nuclear Regulatory Commission. A summary of the original and open items is presented below. Specific details regarding each category are provided in the following attachments:

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• Nuclear Regulatory Commission Palisades Nuclear Plant Update to Action Items July 29, 1988 Category Attachment Total Open July 27, 1988

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Material Condition 1 307 97 Task Force System Functional 2 386 69 Evaluation Safety System Functional 3 29 2 Inspection Equipment Issues, IEIR 50-255/

86029 Others 4 263 19 TOTALS 985 187 Thomas C Berdine Administrator, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachments OC0788-0083-NL02

• COMMITMENTS MADE

1. 3 From the 12/1/86 CPCo response, change commitment as follows:

Commitment No. Change 169, 170, 171 Due Date to 1989 Maintenance Outage 251 Due Date to Refout 88 318 Due Dates to Fiv~-Year Plan 87 Repair valve CV-0521 rather than replace 102 Inspect and repair only the internals of P-52C during Refout 88. Evaluate during further plant operation to determine i f simila_r action. is appropriate for P-52A; P-52B 149 Not necessary to replace valves CV-2153, CV-2155, CV-2165 163 Due Date to Five-Year Plan 177 Facility Change will not be developed 179 Additional evaluation is required during plant operation following Refout 88

• repairs 183 Effects of repair will be evaluated to determine *if valve replacement is still necessary following Ref out 88 188 Additional evaluations are. required 196 No change to surveillance procedures are necessary 241 Remove original recorder following installation of new reorder as part of core cooling modification (Ref. # 254)

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• Commitment No. Change 244 Defer PCP disass_embly and PM to 1989 Maintenance Outage 254 Remove PTR-0125 following installation of new recorder as part of core cooling modification (Ref. #241) 297 Replace monitor R2A-0707 in 1989 339 Original pilot valve replacement plans will' not be completed 344 Existing limit switch will not be replaced 77, 78, 81', 80 Change due date to 1991 362 Cross-reference to our 11/17/87 and 3/29/88 letters 360 Delete CEOG effort and include as Plant life extension effort with data colletion beginning in 1989 361 Include as Plant life extension effort with data collection beginning in 1989

1. 4 From 4/16/87 CPCo response, chang~ due date to 1991

1. 5 From 1/21/87 CPCo response, change due date Commitment 1106 of 12/1/86 letter HPSI mini flow modification to Refout 88 Commitment #23 of 12/1/86 letter Rebuild non-Q operator to Refout 88 OC0788-0083-NL02

• ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 MATERIAL CONDITION TASK FORCE July 29, 1988 4 Pages OC0788-0083-NL02

ATTACHMENT I Material Condition Task Force The intent of the 1986 Material Condition Task Force (MCTF) was to review all known equipment problems or concerns and recommend appropriate followup actions. Therefore, MCTF actions are equipment related improvements or evaluations intended to enhance Plant performance and reliability. The original MCTF effort identified 307 actions or evaluations. To date, 210 items have been completed. Of the remaining 97 items, 44 are scheduled for the September 1988 refueling outage and 41 are defined as long-term improve-ments within the Palisades Plant Five Year Plan. Of the remaining items, five have been deferred from their original completion date, and 15 are clarifi-cations of the original planned action. Details on these items are provided below.

The following items have been deferred from their previously planned completion dates:

December 1, 1986 MCTF.

Item Number Designator Status 169, 170 and EPS-04 These three items pertain to the fuel 171 oil supply for the diesel generators.

Specifically, they address the provision of additional storage capacity, procure-ment of a spare fuel oil transfer pump and providing a secondary containment for the fuel oil storage tank. These ite.ms have been deferred from Refout 88 and are presently scheduled to be completed in the planned 1989 Maintenance .

Outage. No overriding operator concerns or impact on Plant safety were identified which were not addressed by the Plant's present system.

251 PCS-13 The original item called an evaluation/

modification of the pressurizer heater breakers due to poor component reliability.

The evaluation regarding potential replacement is still ongoing with evaluation completion expected during Refout 88. Since this item was originated, component perfor-mance/reliability has significantly increased. This trend is being evaluated against past performance.

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2 318 SWS-01 The original item called for inspection of Service Water System (SWS) valves manufactured by Allis.Chalmers for potential valve seat erosion. The valves not yet inspected and originally scheduled for Ref out 88 have been deferred into the Palisades Plant Five Year Plan. Inspection would require provisions for alternate shutdown cooling.

This provision was also required for CCW heat exchanger replacement, however, the heat exchanger project remains under evaluation and it is not beneficial to establish alternate shutdown cooling only for valve inspection. No immediate operator concern has been noted regarding valve inspection.

The following are clarifications of actions from those origi~ally planned:

December 1, 1986 MCFT Item Number Designator Status 87 AFW-06 Original pl.~ms called for the replace-*

ment of control valve cv~0521. Current plans are to repair the valve rather than replace it.

102 CCS-02 Current plans are to inspect and repair, as necessary, the internals of only component cooling wa*ter pump P-52C in Refout 88. The results of this action.will be evaluated during further Plant operation to determine the need for similar action on P-52A and P-52B.

149 CVC-13 Control valves CV-2153, 2155 and 2165 were recently repaired and have since performed satisfactorily. Original plans for valve replacement during Refout 88 will not be completed.

163 DTA-02 Plans for replacement of the Plant sequence of events monitor and data-logging system will not be completed by Refout 88 as originally scheduled.

However, replacement of the PIP, SP!

and Plant data-logger will be completed under the Palisades Five Year Plan. -

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3 177 ESS-02 . The original f tem called for the initiation of a contingent Facility Change package for safety injection checkvalve replacement. The contin-gency plan has been developed, however, a Facility Change will not be developed.

179 ESS-03 A vendor evaluation determined safety injection pressure control valves and fill and drain valve leakage was acceptable in this application. Repairs will be effected this Refout for known leakers. Effects of repairs will be evaluated during future Plant operation.

183 ESS-05 Shutdown cooling heat exchanger inlet and outlet control valves will be repaired as necessary to control leakage by the valve seat. The effects of these repairs will be evaluated duripg future Plant operation to determine if original plans for valve replacement are still warranted..

• 188 ESS-11 Engineering evaluations have been undertaken. Problems still exist.

Further evaluations are in progress.

196 ESS-24 Containment spray valves CV-3001 and CV-3002 have been repaired. After further review of the surveillance procedure by Operations Department personnel, it has been decided that no changes will be made to the surveillance procedures.

241 PCS-07 Primary coolant system loop measurement channel recorder for TS-0115 and PS-0115 were originally planned for replacement in Refout 88. This action will not be taken in that a new recorder is being added which will record the same information as part of the core cooling instrumentation modification scheduled for Refout 88. After the modification is complete, plans are for original recorder removal.

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4 244 PCS-11 Primary coolant pump motor disassembly and preventive maintenance has been deferred until the 1989 Maintenance Outage. Primary coolant pump motor instrumentation was repaired during the 1987 Maintenance Outage while motor bearings were being inspected and repaired.

254 PCS-15 This item will be dispositioned like PCS-07 above. The core cooling inst-rumentation modification will provide a new recorder. After completion of the modification, PTR-0125 will be removed rather than replaced.

297 RIA-25 Previous plans called for removal of steam generator blowdown monitor RIA-0707 since its use did not support Plant operations. However, since the- intro-duction of boric acid into the secondary side water, a reliable moriitor is again felt necessary to monitor radioactive rel~ases when batching steam generators. The monitor is currently planned for replace-ment in 1989.

339 TGS-07 A modification was performed .to increas*e reliability and require less auxiliary operator attention. This modification has improved pilot valve operation and therefore, original replacement valve replacement plans will not be completed.

344 TGS-12 Per vendor recommendations regarding limit switch application and operation, the existing limit switch will be main-tained _rather than replaced.

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ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 SYSTEM FUNCTIONAL EVALUATION July 29, 1988 I Page OC0788-0083-NL02

ATTACHMENT II System Functional Evaluation The original efforts under the System Function Evaluation (SFE) program were an in-depth comparison of Palisades Final Safety Analysis Report (FSAR) statements and emergency and normal operating procedures against known plant operating characteristics and existing tests. The goal of the SFE was to ascertain that plant systems met design intent through formalized testing or plant operation.

Testing was conducted prior to plant restart in April 1987 where proper system/equipment operation. was not verifiable by existing tests or equipment performance histories. This portion of the SFE required 110 tests be performed. The results of these tests were transmitted to the Nuclear Regulatory Commission, Region III staff in June 1987. Followup efforts to these one time startup tests and other SFE review outcomes resulted in 214 subsequent action items. A later technical review of the original SFE program by Plant pe~sonnel resulted in 62 additional actions.*

To date, 82 percent of the total SFE items have been completed. As stated in the June 24, 1988 meeting, the remainder of the items*(except those which require outage c.onditions to be performed) will be completed by September 9, 1988. An SFE close-out summary detailing each item and overall

_SFE program results will be transmitted to the Nuclear Regulatory Commission by the.end of September 1988.

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ATTACHMENT 3 Consumers Power Company Palisades Plant Docket 50-255 SAFETY SYSTEM FUNCTIONAL INSPECTION July 29, 1988 1 Pages OC0788-0083-NL02

ATTACHMENT I II Safety System Functional Inspection The Safety System Functional Inspection (SSFI), IE Inspection Report

• 50-255/86029, conducted by the NRC from September 22 to October 24, 1986 involved an assessment of the operational readiness and functionality of the

• Plant's High Pressure Safety Injection System (HPSI). During the inspection, attention was focused around the details of original HPSI system design and modifications, maintenance efforts and current system operation. From the original 29 actions, two equipment issues remain to be completed as detailed below:

Action Item Discussion Schedule Modify HPSI miniflow *Past HPSI test results revealed Refout 88 piping to enhance that HPSI pumps may not be dev-testing eloping the minimum recirculation flow required. This recirculation flow is needed to prevent pump damage resulting from overheating when the HPSI pumps are operated against a shutoff head.

Rebuild non-Q Past preventive maintenance efforts Refout 88 Limitorque ope~ators did not require lubrication of motor-operated valves (MOV). Q-Limitorque operators have been rebuilt and tested. ~esults were provided as Palisades response to IE Bulletin 85-03. Remaining non-Q Limitorque operators will be rebuilt as specified.

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ATTACHMENT 4 Consumers Power Company Palisades Plant Docket 50-255 OTHER ISSUES CATEGORY July 29, 1988 3 Pages OC0788-0083-NL02

ATTACHMENT IV Other Issues Category The actions which remain open under this category represent equipment issues beyond the MCTF and other Plant instituted improvement programs. These commitments represent ongoing long-term efforts to improve Plant performance and reliability.

Configuration Control Project (CCP)

In Section 2-III.G.B of Consumers Power Company's lette.r dated December 1, 1986, the following actions regarding Phase I of the Configuration Control Project (CCP) were identified.

1. Assemble a Consumers Power Company System Evaluation Group,

2. Select systems which have vital safety functions and vital support functions,

3. Complete a comprehensive review of these systems by the System Evaluation Group (SEG) and

4. Issue a report on the results of the review.

The purpose of the (SEG) was fulfilled by the System Function Evaluation. (SFE) Team which performed in-depth reviews of each of 33 systems in arriving at the 12.

systems selected for needing further immediate and long-term improvements,'

A report i'Phase I Preliminary Assessment ... Configuration Management" was issued internally in August 12, 1987. The actions in regard to Phase I are considered complete.

In addition, in Section 2-III.G.B. of the same response, Consumers Power Company made the following commitments in regard to the Phase II of CCP.

1. "Review the above (Phase II) activities by the System Evaluation Group"'

and,

2. "It is anticipated that Phase I of the program will be completed in four to six months, while Phase II will require two to three years."

Rather than establish the SEG for Phase II, Consumers Power Company has formed a Technical Advisory Group (TAG) to .oversee the CCP Scope as required by Commitment 1. The SFE Team which performed in-depth reviews of each 33 systems, selected the 12 systems for inclusion in the CCP scope. It is intended that the CCP Scope will be monitored and approved by TAG for these 12 systems and for additional systems as appropriate in the future.

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2 The following provides a listing of necessary clarifications regarding the CCP effort:

Letter Date and Item No. Description Status 12/1/86 Complete a reconstitution This item is currently 77 of Plant design basis scheduled for completion in 1991, rather than the previous schedule of 1990.

12/1/86 Complete verification Same as Item 77 above.

78 walkdowns 4/16/87 Complete Wiring Diagram Same as Item 77 above.

3 Verification and drawing update.

12/1/86 Resolve all issues raised Barring the identi-81 in the CCP Phase II review fication of any "major" issues, this Item will be completed in 1991.

12/1/86 Implement an ongoing This item wiil be 80 Configuration Control completed concurrently program to maintain with items 77, 78 and 81 control of configuration in the future.

Listed below are additional clarifications regarding certain ongoing long-term efforts .to improve Plant performance.

Letter Date and Item No. Description Status 12/1 /86 Add certified internals Actions to be taken 362 to pressure operated in regard to this Item relief valves (PORVs) were detailed in or remove and test PORVs~ Consumers Power's Also, new certified letters dated block valves will be November 17, 1987 and installed. March 29, 1988.

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• 3 12/1/86 Certain primary coolant Transient documentation 360 system transients are requirements were to not being logged. be included in a CEOG effort which has since been cancelled.

Plans now are to include this in the Plant life extension effort with data collection beginning by next year.

12/1/86 Certain steam generator Same as Item 360 above.

361 transients are not being logged.

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