ML18059A931
| ML18059A931 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/08/1994 |
| From: | ROGERS D W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9404150058 | |
| Download: ML18059A931 (13) | |
See also: IR 05000255/1994002
Text
consumers
Power l'OWERINli
MICHlliAN-S
PIUlliRESS
Palisades
Nuclear Plant: 27780 Blu.e Star Memorial Highway, Covert, Ml 49043 April 8, 1994 Nuclear Regulatory
Commission
Document Control Desk Washington, DC 20555 David W. Rogers Plant Safety and Licensing
Director DOCKET 50-255 -LICENSE DPR-20 -PALISADES
PLANT -RESPONSE TO NRC INSPECTION
REPORT 94002, SERVICE WATER OPERATIONAL
PERFORMANCE
INSPECTION, UNRESOLVED
ITEMS AND WEAKNESSES
A Service Water System Operational
Performance
Inspection (SWSOPI) was conducted
at the Palisades
plant over the period from
10 through February 11, 1994. The report addressed
a number of unresolved
issues and weaknesses
for which we were asked to provide a response addressing
eath of these items including
our proposed corrective
actions. A specific
for providing
this response was not requested
in the inspection
report letter. Discussions
with the NRC inspection
team leader resulted in agreemerit
on a response date of April 8, 1994. * A ptoject team has been formed as a followup to the SWSOPI Inspection.
The team is presently
developing
a project plan which will at a
address completibn
of the actions identified
as followup to NRC Inspection
and a margin enhancement
plan for.the service water
Attached to this letter is the individual
responses
to each of the unresolved
items and weaknesses
identified
in the March 4, 1994 inspection
report. David W
Plant Safety and Licensing
Director CC:
Region Ill, USNRC Resident _lnspectori
Palisades
Attachment ('\. ;'"\ ::*, 9404150058
PDR ADOCK 05000255 Q PDR A CMSCNE7?GYCOMPANY
- ATTACHMENT
Consumers
Power Company Palisades
Plant Docket 50-255 RESPONSE TO NRC INSPECTION
REPORT 94-002 SERVICE WATER OPERATIONAL
PERFORMANCE
INSPECTION
.. . UNRESOLVED
ITEMS ANO WEAKNESSES
April 8, 1994 * .
- -* SERVICE WATER OPERATIONAL
PERFORMANCE
INSPECTION
UNRESOLVED
ITEMS AND WEAKNESSES
UNRESOLVED
ITEMS Unresolved
Item 50-255/92028-03(DRS)
1 . Use of firewater
to provide backup water supply for auxiliary
feedwater (AFW). The NRC's concern was based on the lack of an analysis or testing to verify the fire water system's capability
to provide backup water to the AFW system. *The licensee committed
to complete an analysis to document the fire water
adequacy under action item request (AIR) A-PAL-92-098.
- CPCo Response As part of the follbwup to NRC Inspection
Repcirt 92028, we were asked to respond within 60 days of the date of the report, to.Unresolved
Item 3. Our March 29, 1993 lettet to the NRC
our plans for completion
of the follow-up
actions for this unresolved
item. In summary, based on
judgement
we believe that the fire water pumps and interconnecting
system can provide the needed water to the auxiliary
pumps suction. Action . Item Record -A-PAL-92-098
was written to provide an analysis demonstrating
the ability of.the fire water system to provide backup to the Auxiliary
Pumps. The target date for completion_of
the analysis is December 1994. Unresolved
Item 50-255/94002-01
- The team identified
the 1 ack of over-pressure
protection
for CCW heat exchangers (HX) E-54A and E-548. The concern *i nvo 1 ved over-pressure
due to thermal expansion
stemming from service water valve isolation.
Palisades's
ASHE Code of record required each vessel to be protected
from any conditians
specified
in the certified
design specification.
The code further required to document the degree of over.:pressure
protection
in a summary technical
report. The licensee was unable to retrieve the summary technical
report that justified
the lack.of over-pressure
protection
prior to completion
of the inspection.
The licensee committed
to locate the report or perform the * technical
analysis to show Code compliance.
CPCo Response h*ve requested
the original plant architectural
engineer to complete a final search for the code-related
documentation
for the CCW heat exchangers
by May 6, 1994. If the search is
we will review the documentation
for acceptability.
If this search is unsuccessful, a summary technical
report documenting
whether over-pressure
protection
is needed will be
The issue of documentation
for the over pressure protection
of the CCW heat exchanger
will be completed
by June 15, 1994.
- Unresolved
Item 50-255/94002-02
r The results of tests, ca7Cu7ations
and engineering
evaluations
were inconclusive
and could not be used to determine
if the SWS would fu1fi17 its safety related function at elevated Jake water temperatures
combined .with other adverse design basis conditions.
2 The licensee conc7uded
that the SW and CCW systems were currently
operable because current 7 ake water temp.eratures
were 7 ess than 50"F. This temperature
provided significant
margin to account for a77 issues impacting
the SW operability
margin. The licensee committed
to resolve the following
issues, documented
in DR D-PAL-93-272, by mid April 1994. A. Neither test results or design basis calculations
accounted
for * instrument
uncertainties.
8. The analyses that develop required flow. rates to HXs served by* the SWS used only the original design fouling. No calculations
had been performed
to eva 1 uate degraded HX performance
resu]ti ng from f ou 1 ing beyond the original design value. c. D. The most limiting system lineup may not have been teste.d. The impact of increased
sw*temperatures
and reduced SW f7ow rates on the SW and CCW design pressures
and tempera.tures
and systenis'
operation
was not .evaluated.
- E. The root cause of declining
flow rates to control room chi77ers VX-10 and VX-11 had not been determined.
- * F. As discussed
in Section 8.1, the SW pump.IST reference
values and pump degradation
was not coupled to the required system
G. The elevated lake water temperature
was. not incorporated
into the maximum allowable
SW system degradation . . Pending the licensee's
completion
of a77 the actions impacting
SWS margin documented
in DR D-PAL-93-272
and review by the NRC, this is considered
an unresolved
item (50-255194002-02).
CPCo Response We have made an operability
determination, as documented
in D-PAL-93-272, which concludes
that plant operation
up to 50°F lake temperature
is acceptable.
A
of historical
plant records show that the temperature
of Lake Michigan begins to approach a.nominal
temperature
of 50°F during the first part of May.
The lake temperature
limft of SO"F is being tracked on the plant Limiting Condition
for Operations (LCO} control board in the shift supervisors
office which tracks conditions
which effect plant operability.
As the evaluations
listed below progress and issues and uncertainties
are better understood, the operability
determination
may be revised. Such operability
determinations
will be documented
in an engineering
analysis and subjected
to appropriate
technical
reviews. As a result, the target completion
dates to attain a *maximum SWS inlet temperature
may be changed accordingly.
3 A. Action will be taken to account for instrument
uncertainties
associated
with the SWS and-CCW testing in an overall reanalysis*
of the syste_ms through coirective
action D-PAL-93-272.
The target date for completiori
of the
- is May 8, 1994. ?. An additional
action to evaluate the link between analysis inputs and assumptions
used in testing practices
will also be completed
under corrective
action D-PAL-93-272
and is targeted for completion
by August 1, 1994. B. An evaluation
of
fouling
made in heat exchanger
performance
calculations
will be completed.
The evaluation
will determine
appropriate
fouling factors based on Tubular Exchanger
- Manufacturers
As_soci at ion (TEMA} recommendat
i ans for existing service conditions, plus a review of existing maintenance
and testing practices
to determine
where degraded fouling assumptions
may be appropriate.
The target date for completion
of the corrective
action is May 8, 1994. C. An
to assure that the most limiting
hydraulic
lineup is considered
in our analysis will* be conducted
under D-PAL-93-272.
The current date for completion
of the corrective
action is May 8, 1994 .. D. An analysis to evaluate the impact of the elevated SWS _and CCW temperatures
on system design ratings and performance
will be completed
as corrective
actions under D-PAL-93-272.
The target date for completion
of this corrective
action is May 8, 1994. E. A corrective
action has been initiated
under D-PAL-93-272
which requires system engineering
to determine
and correct the cause of the reduced flow *to VC-10 and VC-11. The present plan to accomplish
this action includes a boroscope
inspection
of the subject service water piping to verify the piping is not fouled. We will also be looking at the instrumentation
for accuracy issues and tubing silting problems that may be contributing
to . *this apparent low flow scenario.
Based on these results, actions correcting
the deficiencies
will be taken .. These actions will be completed
during the 1995 refueling
outage. F. A corrective
action has been initiated
under D-PAL-93-272
to develop reference
values for SWS pump testing (IST} which are related to the design basis and accident analysis.
The corrective
action includes
- 4 rev1s1on as necessary
of the appropriate
test procedures.
The target date for completion
of this corrective
action in June 15, 1994. G. Reanalysis
of the SWS performance
will ensure that the appropriate
maximum SWS inlet temperatures
are evaluated
along with the maximum expected system degradation.
This analysis will be completed
as a corrective
- action under
The target date for completion
of the corrective
action is May 8, 1994. Unresolved
Item 50-255/94002-03
Corrective
actions in response to D-PAL-93-272
wi71 comple{e the development
of SWS pump testing reference
values and
system performance.
Additiona71y, the licensee intended to review the basis for IST reference
values and a77owed degradation
for a71 Section XI pump tests to ensure tha.t they were adequately
coordinated
with safety analysis performance
criteria.
This issue is considered
an unresolved
item pending the licensee's
review to determine
impact on the IST reference
values *and the possible effect on past ESS pump operability.
CPto.Response
As noted in response to
50-255/94002-02
Item F,. a corrective
action has been initiated
under D-PAL-93-272
to develop reference
values for SWS pump testing which are related to the design performance.
A
action was written under D-PAL-93-272
to develop a basis for reference
values for all safety related pumps in the Inservice
Test Program which are directly related to the design basis and accident analysis.
The corrective
action requires revision, as necessary;
of the appropriate
test procedures.
After the ISI pump reference
values are
reviews will be completed
to determine
the affect, if any, on past ESS pump bperability . . The target date for completion
of the corrective
action is August 1, 1994. WEAKNESSES
NRC Identified
Weakness The NRC inspectors
ran several scenarios
on the plant simulator.
The first *scenario
required*
the crew to isolate SWS critical header A to stop a leak. The SWS critical header A leak, .which was located in the CCW pump room, was not isolated until 30 minutes after the event was identified
by the crew. This created the potential
for flooding of the CCW pump room. Because procedure
ONP 6.1, "Loss Of Service Water," Revision 5, did not cont*atn any specific guidance to isolate the leak, operator aid (DA) 136 was
- used,to determine
which valves should be closed to determine
leak location.
OA 136 was a SWS simplified
schematic
that was attached to the control panel. Although the crew successfu17y
isolated the SWS leak, identified
leak location, and determined
the impact on plant operation, the team considered
the delay to complete leak isolation
actions a weakness.
CPCo Response 5 . The simulator.scenario
consisted
of a service water line leak in the CCW Room on the 'A' Critical Service Water Header. The crew suspected
a service water system leak when the SWS standby pump
and critical service water system header pressures
dropped significantly.
The Shift Supervisor
subsequently
ordered an
down power, however during the down power, the plant was tripped due to voltage regulator
problems.
While the crew commenced
EOP 1.0, "Standard
Post Trip Actions," immediate
actions a LOCA event was
Shartly after completing
EOP 1.0, the LOCA was. identified
and the crew focused their immediate
priorities
on the LOCA since the service water critical header pressures
remained above the Safety Function
Check Acceptance
of 42 psig. After sufficient
action was taken on the LOCA, the crew re-directed
their efforts to isolating
the SWS leak which was approximately
30 minutes later: . -* *The following
actions will be performed
to enhance operator*response
in identifying
SWS leaks: 1. We will enhance ONP 6.1, "Loss of
Water," to effectively
proceduralize
a leak isolation
process. However, the procedure
will be changed only if we are sure that the probability
of
efficient
leak isolation
efforts is low. * 2. Additional
simulator
will be completed
on ONP 6.1, "Loss of Service Water." NRC Identified
Weakness This weakness identified
in the licensee's
operating
SOP 16, Steps 5.1.2 and 7.6 prevented
initiation*
of backup coo-Jing from the SWS to the ESS pumps if norma 1 coo*1 i ng from CCW was 1 ost concurrent
with an SI signal. Procedure
compliance
would prohibit opening the SWS valves to the ESS pumps with the CCW valves open. The CCW valves would remain open until the SI signal could be reset. Current procedural
compliance
results in loss of cooling water to the ESS pumps. The licensee indicated
that the procedure
would be revised to allow opening the SWS valves to the ESS pumps if the CCW valves were open and an SI signal was present. A CAUTION preceding
step 7.6 would also be added to alert the operator that CCW would drain to Lake Michigan with a resultant
loss of CCW
Cooling Water (CCW) System Procedure," Step 7.6 provides an option of supplying
service water to the ESS pumps with a loss of CCW cooling supply. This section required closure of the CCW supply and return valves prior to opening the SWS supply and return valves. A precaution, Step 5.1.2, also noted that the CCW supply and return valves shall not be open when the SWS supply and return valves are open since this would allow CCW system water drainage to the lake. The
could have been interpreted
as *: environmental
issue only. The procedure
also did not
address the* case when an SIAS signal was present and the CCW supply and return valves. could.not
be closed. The fo 11 owing actions wi 11 be performed
to correct this procedural
weakness:.
1. A caution was added to SOP 16, Section 7.6, identifying
the inability
to close the CCW supply and return valves with an SIAS si.gnal. The caution also indicates
that if the
water cooling option is performed, the.* CCW system will drain to the lake and CCW cooling to other plant equipment
would be lost. This action is completed . 2. SOP 16,
was revised to clearly._identify
the result* of draining CCW system to the lake. This actibn was completed.
3. SOP 16, Sections 7.6 and Step 5.1.2 will be revised in accordanc'e
with the* engineering
resolution
for resolving
the single failure
This action will be completed
after engineering
resolution
of the single *
vulnerability
of the CCW system. NRC Identified
Weakness This weakness was identified
in the licensee's
operating
procedures.
SOP 15, "Service Water System," Revision 7, Step 4.1.2 contained
a similar statement
as described
above. The licensee indicated
that this procedure . would be revised. CPCo Response The SOP 15, Revision 7, Step 4.1.2, requirement
coincides
with the requirement
of SOP 16, Step 5.1.2 .. SOP 15, Step 4.1.2 will be revised in
with the engineering
resolution
for resolving
the single failure concern. This action will be completed
after the engineering
resolution
of the single
vulnerability
of the CCW system.
- 7 NRC Identified
Weakness *This weakness was
in the licensee's
operating
Response Procedure (ARP) 7, Window 29, "Service Water Bay 1 ow Level," did not provide guidance regarding
what level SW pumps should be . tripped if SW bay level was decreasing.
Thfs item was previously
identified
during the licensee's
SSDC conducted
in Hay 1990. The licensee indicated
that the procedure
would be revised. CPCo Response ARP 7, Window 29 will be revised tb provide
directions
to
for tripping the service water pumps. NRC Identified
Weakness This weakness was identified
in the licensee's
operating
procedures.
ONP 6.1, Revision 5, Attachment
1, "Alternate
Method of Supplying
the Intake* Structure," requited tripping the SW pumps if warm water recirculation
pump f P-5) was used to supply water to the intake structure.
This did not coincide *with SOP-14, "Circulating
Water and Chlorination
Systems," Revision 16, step 7.13.1, which provided steps to supply the intake structure
from P-5 but did. not require tripping the SW pumps. The licensee indicated
that'guidance
for tripping the SW pumps would be incorporated
into *the appropriate
ARP and removed from ONP 6.1, Attachment
1. No revisions
to SOP 14 were deemed necessary.
- CPCo Response ONP 6.1, Revision 5, Attachment
1, was developed
on the assumption
of a collapsed
intake piping or crib. The result of such a collapse would be an immediate
emptying of the intake pump bay, therefore, the procedure
ensured that the SWS and dilution water pumps were tripped off. SOP 14, Step 7.13.1 was developed
as a warm water supply to melt ice off the traveling
screens, which does not necessarily
tripping of the SWS or dilution water pumps. The following
actions will be performed
to correct this procedural
weakness:.
1. ONP 6.1 has been revised to require tripping of the dilution water pumps only based on water cohservation
for the SWS system. 2. The ARP 7 will be revised to provide direction
when the SWS and dilution water pumps should be tripped off.
8 NRC Identified
Weakness The team identified
non-seismica11y
constructed
scaffolding, insta11ed
in the. west safeguards
room over safety-related
equipment.
The licensee performed
an engineering
analysis, which concluded
that the scaffolding
did not meet the * requirements
of procedure
HSH-H-43, "Scaffolding,".
Revision O, but was not a
concern. The licensee removed the scaffolding
and initiated
a revision to HSH-H-43 that provided additional
instructions
for scaffotding
in related areas. The revision would include walkdown inspections, supervisor
sign-off for installation, clarification
of requirements, and approval and justification
by the system or assigned engineer for deviations
from the procedure.
The team considered
this action acceptable.
- CPCo Response On January 20, 1994, NECO Civil
performed
an analysis for scaffolding
and concluded
the scaffolding
did not
the requirements
of Procedure
MSM-M-43.
However, the scaffolding
did not reflect a safety concern. On January 21, 1994, plant maintenance
personnel
performed
a walkdown and found only one qther scaffold installed
in the plant. The installed
scaffold met the installation
requirements
of procedure
MSM-M-43 and there was no safety-related
equipment
involved.
On January 22, 1994, plant maintenance
repair workers dismantled
and removed the scaffolding
from the. West Engineering
Room. * As a result of this event the following
corrective
actidns will be taken: . . . 1. Procedure
MSM-M-43 will be revised to include (1) instructions
for walkdown inspection
for scaffolding
installed
in safety-related
areas; (2) a supervisor
sign-off for scaffolding
installed
in safety-related
areas; and (3) to clarify requirements (for free-standing, separation
_distances, braced scaffold, etc.) as they relate to requirements
for scaffolds
installed
in safety-related
,\ 2. Responsible
maintenance
supervisors
will be informed of the requirement
that any deviations
from the Procedure
MSM-M-43, with regard to general scaffolding
requirements
and requirements
for scaffolds
in safety-related
areas, require approval and justification
by engineering
before the scaffolding
can be accepted for use. 3. Training will be provided for Plant Maintenance
Supervisors
on their
ities
permanent
Maintenance
Procedure
MSM-M-43.
NRC Identified
Weakness The team identified
that a ground strap was not connected
on an recently replace containment
spray pump motor. DR D-PAL-94-017, evaluated
the problem . and co.ncluded
that the work package instruction
lacked the detail necessary
to ensure the ground strap connection.
The package also contained
other minor ;
discrepancies
as we17. The.licensee
the ground strap and was *developing
corrective
actions for the other minor deficiencies.
The team* considered
this attion acceptable.
CPCo Resoonse 9 The root cause of the condition (unconnected
ground strap) described
on . Deviation
Report (DR) D-PAL-94-017
can be attributed
to an inadequate
job plan on Work Order (WO) 24202957.
This WO plan did not contain sufficient
detail to ensure that the work would be
properly.
A procedure
exists (ESS-E-36)
that contains detailed steps concerning
the re-connection
of the ground strap on the motor, EMA-1114.
While.there
is no requirement
to use this procedure
for the replacement
of the motor, the WO plan should c6ntain an equivalent
amount of detail. * While reviewing
the WO package and related documentation, the following
discrepancies
were also noted and corrective
actions will be assigned to" address them as well. 1. The WO plan called for motor removal,
for refurbishment, and. reinstallation
of same motor. The spare motor from stock was used to problems
refurbishment
of the
motor and the WO plan was not. revised to reflect the subtle differences
between the spare motor and the one that had been removed from the pump. 2. The Work Instruction (WI) WI-SPS-E-02
data sheet was not
filled out, in that the motor serial number was not listed as required.
3. Procedures
ESS-E-36 and MSE-E-5
the procedure
and all* attachments
to be filed in DCC
filmed). The WO package was purged of these
prior to closeout and therefore
this requirement
was not met. 4.' Several entries on the WO summary as well as a *signature
in FHS-M:.23
did not contain dates. -I 5. The WO package did not contain the issue ticket for the Raychem cable splices used during the reconnection
of the motor.* 6. The equipment
database has not been revised to reflect the serial number of spare motor that was installed . . ]. The radiation
hot work permit does not provide a box to be checked that
the use of a torch for heating. * 8. Torquing of the motor hold down bolts was signed as performed
on July 10, 1993 and verified on July 11*, 1993. This activity was in fact performed
on July 11, 1993. 9. * Step 9 of the WO plan contained
a double verification
that the WO summary shows was performed
on July 8, 1993 but was signed July 19, 1993.
10 Corrective
Actions 1. The evaluation
of this investigation (D-PAL-94-017)
and its associated
WO will be reviewed with members of the maintenance
department
specifically
addressing
items 1, 2, 4, 5, 8, and 9 listed above. 2. The practice and control used to revise the database
when a spare motor is installed
will be evaluated
to determine
if current practice is acceptable
or if the method should be modified to ensure timely database update. 3. An assessment
will be completed
to
the need to revise. the hot wbrk permit form to include a box to be checked to address heating with a torch. 4. All'permanent
maintenance
procedures
will be reviewed to determine
which .ones
the filming of all attachments.
Those permanent
maintenance
procedures
whose filming requirements
need to be clarified, will be revised following review. NRC Identified
Weakness The team found that the licensee had not fully evaluated
the susceptibility
of SWS instrument
line fouling. Specific flushing requirements
had only been implemented
for instruments
that had been clogged in the past; however, walkdowns
of SWS pump discharge
lines found that instrument
lines to pressure switches for standby pump starting had long stagnant.horizontal
runs that might be subject to fouling. These lines were.not checked by periodic maintenance
or surveillance.
Also omitted were stagnant 11nes to and from the former control room air conditioners.
This was not consistent
with the GL intent, which reconunended
licensees
establish
routine maintenance
of. SWS piping and components
to ensure that silting and bio-fouling
could not degrade system performance.'
The licensee conunitted
to review the.maintenance
of these and other instrument
lines. CPCo Response It is apparent that the original Generic Letter 89-13 effort did not address all instrument
lines. During the Palisades
SWOPI inspection
the NRC Information
Notice 94-003 was issued. The Information
Notice entitled, "Deficiencies
Identified
During *service Water System Operational
notifies licensees
of concerns regarding
instrument
tubing becoming fouled with silt and. acknowledges
that this issue should have been better addressed
by the Generic Letter 89-13 implementation.
We will review the specific issues in the Information
Notice to see how those issues apply to Palisades,
.. ** 11 and incorporate
actions as need&d in our preventative
maintenance
program to ensure that tubing doesn't become fouled. The review of the Information
Notice and any corrective
needed will be completed
by the end of the 1995 refueling
outage. An AIR, A-PAL-94-009, initiated
to assure that the -issue of the stagnant lines to and from the former control room air conditioners
is addressed
under the Generic Letter and Information
Notice 94:004 guidelines.